Clandestine Drug Lab Cleanup

UC Davis Extension continuing education Since 1891

Clandestine Drug Lab Cleanup

A HAZWOPER Supplement

April 25, 2006

Instructors:

Mark Cameron, CIH Elise Rothschild

Mark Trask

Western Region Universities Consortium (WRUC) - NIEHS Grant

UC Davis Extension Occupational & Environmental Management

1333 Research Park Drive Davis, CA 95616 (530) 757-8607

CLANDESTINE DRUG LAB CLEANUP - A HAZWOPER SUPPLEMENT Learn the new regulations (AB 1078) related to the cleanup of drug lab contaminated properties. Identify the likely chemicals used at drug labs and discuss the possible risks to personnel associated with these chemicals. Explore the analytical methods used for detecting residue and determine applicable cleanup levels. You will also discuss the appropriate cleanup methods used at contaminated properties. This course is designed for HAZWOPER (40 hour) trained personnel who develop cleanup plans, perform actual cleanup and are planning to do inspections of drug lab contaminated facilities. It is also applicable for regulatory personnel who oversee cleanup of drug lab contaminated facilities.

MARK CAMERON, SENIOR INDUSTRIAL HYGIENIST

ELISE ROTHSCHILD, SUPERVISING ENVIRONMENTAL SPECIALIST MARK TRASK, ENVIRONMENTAL SPECIALIST

UC DAVIS EXTENSION Janis Heple, program director Nathan Sands, program representative Whitney Hughes, program assistant Occupational and Environmental Management 1333 Research Park Drive, Room 251 Davis, CA 95616 (530) 757-8607 Western Region Universities Consortium (WRUC) is supported by grant number ES006173 from the National Institute of Environmental Health and Science (NIEHS), NIH. Its contents are solely the responsibility of the authors, and do not necessarily represent the official views of the NIEHS, NIH.

IntroductionC

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Methamphetamine:“What’s the big deal?”

Amphetamine/Methamphetamine

Methylated version of amphetamineName

d-N-methylamphetamined-deoxyephedrine1-phenyl-2-methylaminopropaneCAS: N,a-dimethylbenzenethanamine

Meth 2-15x more potent than amphetamine

Street Names for Methamphetamine

CrystalMethCrystal MethSpeedTweak/TweekProductCrank

TinaCrissyGlassIceUppersYabaShabu shabu

Methamphetamine HistoryAmphetamine synthesized 1887 by German chemist, L. EdeleanoRecent research has shown that methamphetamine was first produced by Dr. Nagayoshi Nagiai of Tokyo Imperial University in 1888 by reducing ephedrine with HI and Red PhosphorusMethamphetamine synthesized from methylamine and phenyl-2-propoanone 1919 by Japanese researcher, A. Ogata1927 (USA): Dextro-levo-amphetamine synthesized as substitute for ma huang (chinese name for the herb ephedra)1930: Amphetamine discovered to increase blood pressure. Marketed in 1932 as “benzedrine” in an over-the-counter inhaler to treat nasal congestion1935: Amphetamine’s stimulant effect first recognized and used to treat narcolepsy (compulsion to sleep)1937: Amphetamine first approved by AMA for sale in tablet form.Sold by prescription for treatment of narcolepsy, ADHD and 37 other conditions.

Meth History Cont.1938: First published report of amphetamine addition and

psychosis1940: “Methedrine” commercial trade name for

methamphetamineBoth amphetamine and methamphetamine used as

performance enhancer by Japanese, German and Americans in WWII. Led to addiction problems in Japanese after the war.1950-53: amphetamine distributed to US troops in Korean war1951: U.S. Congress passes a law requiring prescriptions for all

oral and injectable amphetamines used commonly to treat obesity, narcolepsy and depression.1954: Height of Japanese addiction: 2 million users in 88.5

million population1959: first report of IV injection of contents of benzedrine

inhaler. OTC Benzedrine Inhalers within drawn from market. OTC Methedrine inhalers offered.

Meth History, cont.1962: early reports of illicit domestic production by biker gangs1965: OTC Methedrine inhalers withdrawn from market. 31 million prescriptions written: mostly to women.Amphetamine and methamphetamine become Schedule II drugs in 1971Motorcycle gangs synthesized drug using phenyl-2-propanone until late 1980’s. P2P became restricted substance, so chemistry shifted to making P2P from phenyl acetic acid or other ways1987, DEA busts first HI/Red Phosphorus lab in the country in California. This method has a higher yield and more potent methamphetamine. Mexican nationals take over the market from biker gangs with this method.Current methods (Iodine/Red P or Lithium/Ammonia) using pseudoephedrine became popular as other chemicals became illegal

Source: http://www.usdoj.gov/dea/concern/map_lab_seizures.htmlaccessed October 18, 2005

1990 1994 1997

CA 227 419 946

DEA 520 306 1238 (nationwide)

Source: http://www.usdoj.gov/dea/concern/map_lab_seizures.htmlaccessed October 18, 2005

Modes of Administration

• Harms associated with each:• Slamming (Injection) • Snorting• Swallowing (crystal-laced drinks;

homemade pills: wrapped in tissue paper and ‘popped’ with water)

• Smoking• ‘Booty bumping’ (rectal administration)

Physiological EffectsIncreases heart rate (tachycardia) and blood pressureIncreases shallow breathing (tachypnea)Raises internal body temperature (hyperthermia)Causes sweating, often profuselyDecreases appetiteEnlarges pupilsCauses dry mouth and bad breath (halitosis)Causes pounding headachesIncreases motor activity (can’t keep still)

“Tweaking”

• Tweaking lasts 8-12 hours, depending on dose and purity; may last several days from repeated dosing

• Major symptoms may include:Teeth grindingDilated pupils and staring/trance stateBad breathSevere paranoia and hallucinations Rapid body movement; jerking‘Meth bugs’ (parethesias, caused by an imbalance in sensory neurons) and may lead to picking one’s skin Increased motor activity/performing repetitive acts

Source: http://www.usdoj.gov/dea/concern/meth_effects.html

“Crashing”Withdrawal effect:

Extreme exhaustion Sleep disorder Suicidal ideation Increased generalized anxiety and/or other anxiety disorders (agoraphobia)Can lead to continued use (“crash avoidance”) Using ‘downs’(sleeping pills) and/or opiates to alleviate withdrawal

ConsequencesAdditional problems with meth:

• Impaired cognitive functioning and short-term memory loss, notably abstract thinking and judgment

• A person’s ability to perceive risks and consequences while tweaking is diminished (person may engage in high risk sexual behavior, linked to HIV infection and syphilis)

• Mixing drugs when crashing: pain killers; sleeping pills (may cause Substance Induced Amnesia if the person doesn’t fall asleep)

Consequences of Long-term Use

AddictionSexual compulsivityAnorexia; distorted body image, or phobia about weight gainLethality results from kidney failure, dehydration, seizures (can occur after single use); cardiovascular events such as heart attack or stroke“Meth mouth”: Lack of saliva production causes bacteria to grow, causing tooth decay

“Meth-induced osteoporosis”: structural deterioration of bone tissue, which leads to bone fragility and loss of teeth

Meth Mouth

When meth is ingested, it causes the user's blood vessels to shrink, limiting the steady blood supply that the mouth needs inorder to stay healthy. With repeated shrinking, these vessels die and the oral tissues decay. Similarly, meth use leads to "dry mouth" (xerostomia), and without enough saliva to neutralize the mouth's harsh acids, those acids eat away at the tooth and gums, causing weak spots that are susceptible to cavities. The cavities are then exacerbated by behavior common in users on a meth high: a strong desire for sugary foods and drinks, compulsive tooth grinding, and the general neglect of regular brushing and flossing.

In case you have doubt about the hazards of meth use…

Source: http://www.usdoj.gov/dea/concern/meth_effects.html

Accessed October 18, 2005

Crystal Releases Neurotransmitters

Meth crosses the blood brain barrier and causes release of neurotransmitters:Dopamine: provides feelings of reward and pleasureSerotonin: provides sense of emotional stabilityNorepinephrine: stimulates arousal, drive

Dopamine

Normally, dopamine is released, excites receptor cell, is released and pumped back into adjacent nerve ending.

Drug effects on dopamine

Meth and heroin block the return pump, allowing dopamine to sit on receptor cell and continue firing.

Heroin lasts an hourMeth lasts up to 12 hrs

Damage to Dopamine Transport System

Although speed cause initial flood of dopamine, in the long term, dopamine transport system is damaged.This results in dopamine deficitsDamage, although probably not permanent, is long-lasting and persistent

Damage to Dopamine Transport System

SensitizationPersistence of psychotic symptomsResumption of psychoses with each usePsychosis can be triggered by other substancesCognitive impairment

Cognitive ImpairmentMemoryVerbal LearningJudgmentReasoningPlanning, impulsivity

Meth Mimics AdrenalineAdrenaline prepares the body for emergencies -- to either fight or run.This is known as the “fight or flight” response.The body experiences crystal meth as an emergency, prompting appropriate physiological responses.

“Fight or Flight” Response

The body prepares for an emergency, possible injury:

Pupils dilate to admit more light.

Cutaneous blood vessels constrict.

Bronchial muscles relax increased respiration.

Heart rate and body temp increase.

Ureters, intestines and urinary muscles constrict.

Digestive tract movement inhibited.

Metabolism increases.

Body burns glucose (sugar in muscles) to provide energy.

Physiological Effects

Increased heart beatPupil dilationIncreased body temperatureVasoconstiction- veins shrinkIncreased metabolic rateNausea/vomitingLoss of appetite– anorexia/weight

loss

Impaired speech– jumbled word

orderPerspiration or chillsPsychomotor agitationPsychomotor retardationStrokeHeart failureSeizuresComa

Psychological Effects

AnxietyObsessive/compulsiveEuphoriaHyper-vigilanceTensenessHallucinations– audio (hearing)– visual (sight)– tactile (touch)

Paranoia– fearfulness– mistrust AgitationApprehensivenessGuardednessHyperacute memoryDelusions of– conspiracy– egocentric persecution

Psychosis

Methamphetamine OverdoseToxic buildup of meth levels caused by high ingestion amounts and/or delayed metabolism bdue to clogged liver pathways

Sudden increase in blood pressure causes decrease in oxygen/blood to the brain (face will turn blue).

Body temperature goes up to dangerous levels.

Sweating (to cool down) might not occur.

Increased risk of heart attack, stroke or coma.

User might see spots (due to pressure on the optic nerves in the eye) or pass out.

IntroductionC

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Meth ChemistryMeth Chemistry

Current MethodsCurrent MethodsReducing ephedrine/pseudoephedrine to methamphetamine

HI-red phosphorusAmmonia-lithium (Nazi method)

Old MethodsOld Methods

Reducing ephedrine/pseudoephedrine to methamphetamine

Chlorination and Catalytic: metal catalyst and H2

Reductive Amination of Phenyl-2-propanoneAluminum amalgamCatalytic Hydrogenation

I. HI/Red Phosphorus ReductionI. HI/Red Phosphorus Reduction

P + 3HI PI3 + 3H (combines with –OH) H3PO4 + HI

EphedrineEphedrine

Stereochemistry: 2 chiral center= 4 formsd,l ephedrined,l pseudoephedrine (OH and NH on same side)

l-ephedrine, d-pseudoephedrine produce d-methamphetamineEphedrine used as bronchodilator; pseudoephedrine used as decongestant

PhosphorusPhosphorusRed P can only be ordered out-of-country except as a reagent

Get from match box strike plates– 40% red P, 30% anitmony sufate

Use white phosphorusUse hypophosphorous or phosphorous acid

HazardsFlammable solid (friction)If heated, converts to white phosphorus

– Air reactive flammable solidOff-gasses phosphine, especially when heated

PhosphinePhosphine

Off-gasses during cookPEL = 0.3 ppm, IDLH = 50 ppmAttributed to multiple deaths at clan labsExamples of levels measured in controlled cook situations

Open container of red phosphorus = 1.4 ppmHI/RP cook: 0-13 ppm at sample portMaking HI by mixing I2 and RP: 0-42 ppmHypophosphorous acid cook: 0-85 ppm

IodineIodineSources

Hydriodic acidIodine crystals/prills from commercial sourcesFeed supply (antibiotic, supplement)Make from iodine tincture

HazardsSevere respiratory irritant

– PEL= 0.1 ppmCorrosiveOxidizer

HI/Red Phosphorus Step 1: Tablet ExtractionHI/Red Phosphorus Step 1: Tablet Extraction

Pseudoephedrine tablets ground up using any type of grinderTablets extracted with water or polar solvent (MeOH, denatured alcohol)Filter off pill binder materialEvaporate off solvent to leave pseudoephedrine solid

Fire hazard!!

HI/Red Phosphorus Step 2: Convert to MethHI/Red Phosphorus Step 2: Convert to Meth

Mix red phosphorus, water, pseudo and iodineHeat generated by reaction alone; splatter if not added slowly or in order

Boil for extended period of timePhosphine gas (deadly) and iodine vapor emitted during cook (deadly). Attach hose to top of reaction vessel and run into water, kitty litter.

HI/Red Phosphorus Step 3: IsolateHI/Red Phosphorus Step 3: Isolate

Filter off red phosphorusWaste flammable solid

Make solution basic (>pH 12)Lot of heat generated, volatilizing meth base into the air

Add non-polar solvent to extract methColeman fuel, naptha, lighter fluid, toluene, diethyl ether, freon 11, carbon tetrachloride

– Except for freons and heavily chlorinated solvents, all are very flammable.

Biphasic solution (meth in top layer if solvent lighter than water)

HI/Red Phosphorus Step 4: Salt outHI/Red Phosphorus Step 4: Salt out

Separate off solvent phaseBubble HCl through solvent mixture to make methamphetamine-hydrochloride

Used to use commercial HCl cylindersMake own by mixing coarse salt and sulfuric acid, or muriaticacid and aluminum strips in a closed container with a hose

– Levels measured during controlled cooks exceed IDLH

Evaporate off solvent to have meth powderFlammablility issue again!!

WastesWastes

Red P/iodine mixtures: corrosive, off-gassing irritating or toxic gasesSodium hydroxide mixture: corrosive, some methby-productsWaste solvents

Alcohols with binder materialNon-polar solvents with meth by-products

ContaminationContamination

IodineMethamphetamineHCl residualAcidic/basic spillsFlammable solid residualSolvent residuals

II. Birch Reductionaka: “Nazi Method”II. Birch Reductionaka: “Nazi Method”

Benkeser used THF and lithium instead of sodium. Lithium is commonly substituted for sodium

Birch ReductionBirch Reduction

Mix ground-up pseudoephedrine (no extraction needed) and dry lithium (from batteries)Add anhydrous ammonia until all lithium reactsAdd non-polar solvent to remove methamphetamine baseSalt-out as previously described

Chemical HazardsChemical Hazards

AmmoniaCorrosive, toxic, cryogenic, combustible

LithiumCorrosive, flammable solid, water reactive

Non-polar solventsFlammable, toxic

Ammonia sourcesAmmonia sources

Commercial and farmer nurse tanksMake your own from fertilizer

Ammonium nitrate or sulfateLyeSmall amount of waterRun tube to jar through acetone/dry ice bath to condense waterCollect anhydrous ammonia in jar after ice bath

Wastes from Birch ReductionWastes from Birch Reduction

Basic sludge from ammonia/lithium reactionSolvent wastes from salting-outSalt/sulfuric acid wastes

Contamination from Birch ReductionContamination from Birch Reduction

Methamphetamine residualsFlammable solid residual (water reactive)SolventsHydrogen chloride contamination on surfaces from gassing-out

III. Catalytic reductionIII. Catalytic reduction

Pseudo added to chloroformAdd thionyl chloride and stir 1-4 hrsAdd diethyl ether until precipitatesFilter and dry intermediateAdd methanol, palladium to hydrogenator(pressure vessel)Add hydrogen under pressure until reaction stops absorbing hydrogen

Catalytic reduction hazardsCatalytic reduction hazards

Thionyl chlorideWater reactive, off-gasses sulfur dioxide, HCl

Flammable solvents: methanol, diethyl etherFlammable gas under pressure: hydrogenFlammable solid: palladium

IV. Chemicals in older methodsIV. Chemicals in older methods

Reductive AminationBiker dope (aluminum amalgam)

– Phenyl-2-propanone (P2P)– Methyl amine: smells bad!!– Mercuric chloride: contamination issue– Aluminum foil

Catalytic HydrogenationP2P, N-benzylmethylamine then reacted under pressure with hydrogen, palladium/carbon, platiniumor Raney nickel

V. Make your own P2PV. Make your own P2P

Phenyl acetic acid (PAA) + acetic anhydride + sodium acetate or pyridine P2PPAA + lead (II) acetate + dry distillation P2PBenzaldehyde + nitroethane 1-phenyl-2-nitropropene. Reflux w/ HCl, Fe, FeCl3 P2PBenzyl cyanide, sodium ethoxide, ethyl acetate produce intermediate. Mix with acetic acid and sulfuric P2PPAA, acetic acid reacted in thorium furnace (>400oC) P2P

OEHHA

DEPARTMENT OF TOXICSUBSTANCES CONTROL

AmmoniaRecognizing Ammonia

September 2003

Anhydrous ammonia is a gas at room temperaturebut becomes liquid when pressurized. It is typicallyfound in pressurized steel tanks in a liquid form(Figure 1). Anhydrous ammonia can beobtained from commercial chemical supplycompanies, farms that use it for fertilizer,or from blueprint operations.Note: Direct contact with liquidanhydrous ammonia as it is releasedfrom pressurized tanks can causesevere frostbite.Aqueous (liquid) ammonia forhousehold cleaning (e.g., “Parson’sAmmonia”) is a solution containing 5-10% ammonia gas dissolved in water.Household ammonia is not used inmethamphetamine synthesis.

Role in Drug Synthesis

Containers & Packaging

Ammonia is used with an alkalimetal, typically lithium or sodium, inthe “Nazi” method to synthesizemethamphetamine.

Appearance: Pure anhydrous (i.e., without water) ammonia isa colorless gas at room temperature.Odor: Very sharp, pungent, and suffocating odor. Olfactoryfatigue can occur fairly rapidly, making a person unaware ofincreasing concentrations in the surrounding air.Odor Threshold: Minimum threshold: 5 ppm.Odor Safety Class: C (less than 50% of distracted individualsperceive warning of threshold limit value).Vapor Density: 0.59 (air = 1.0). Ammonia is lighter than air. Butvapors from pressurized ammonia are initially colder andheavier so they may concentrate near the ground or in

depressions until they warm to room temperature and rise.

Figure 1: Anhydrous ammonia gas is stored andtransported as a liquid in pressurized gas containers.Note greenish-blue corrosion on valves and fittings.“Secondary” containers such as these were notdesigned to hold ammonia and may fail at any time.Photo Courtesy of CA Department of Justice.

Health HazardsInhalation Exposure: Vapors at a concentration of 50-100ppm cause nose, throat, and airway irritation. This may lead towheezing, shortness of breath, and chest pain. Inhalation ofconcentrated vapors may result in respiratory tract burns.Exposure to moderate or high vapor concentrations may alsocause swelling in the nasal and upper respiratory tissues andfluid build-up in the lungs. This could result in breathing difficultyor life-threatening respiratory failure.Skin (Dermal) Exposure: Direct contact can result in chemicalburns, which feel soapy due to the action of ammonia on fat intissues. Blistering, deep penetrating burns, and cell and tissuedeath may result. Less severe injury is characterized by gray-yellow soft regions. In severe cases, the skin appears blackand leathery. Frostbite may also result from contact withanhydrous ammonia as it is released from pressurized tanks.

Eye Contact: Vapors at concentrations of 50-100ppm cause irritation, tearing, and inflammation.Higher concentrations can cause severe injury

including burns or temporary blindness.Severe exposure can damage the iris and

cause cataracts. Hemorrhage, extensiveloss of eye pigment, and glaucoma mayalso result. Contact with concentratedaqueous ammonia solutions can causepermanent eye injury, including blindness.Damage extent may not be identified forup to one week after initial injury.Ingestion: Aqueous ammonia solutionsmay cause nausea, vomiting, andswelling of the lips, mouth, and throat.Ingestion of concentrated solutions mayresult in burns to the lips, mouth, andesophagus. Oral exposure does nottypically result in systemic poisoning.Chronic Effects: Repeated exposuremay cause chronic skin, eye, andrespiratory irritation. Chronic cough,asthma, and lung fibrosis may occur.

Vol. 1, No.1: Clandestine Drug Labs/ Methamphetamine

NH4

Clandestine Labs/ Methamphetamine: AmmoniaAmmoniaAmmoniaAmmoniaAmmoniaFirst Aid

Inhalation Exposure: Move to fresh air. Administeroxygen if needed. If breathing difficullty continues, getmedical attention.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed skin and hair with waterfor at least 15 minutes. Seek immediate medical attention. Treatburns as directed by medical personnel.Contact with Eyes: Flush exposed eyes with water or salinesolution for at least 15 minutes. Remove contact lenses if

possible. Seek medical attention.Ingestion (Oral) Exposure: Do notinduce vomiting or administeractivated charcoal. Do not performgastric lavage or attemptneutralization. Conscious victimsshould be given 4-8 ounces ofwater or milk. Seek immediatemedical attention.Special Concerns forChildren: Children may inhalerelatively larger amounts ofammonia vapors due to their faster

breathing rates and greater lung size to body weight ratio.They may also receive higher doses due to their short stature.Ammonia vapors from compressed tanks may initially settleclose to the ground in the typical breathing zone for children.

Handling & Safety

Environmental ConcernsAir: Ammonia gas is readily removed from air via wetdeposition (rainfall), dry deposition, reaction with gas-phasenitric acid to form ammonium nitrate, and reaction with aerosolsto produce ammonium salts.Soil: Soil microorganisms rapidly take up ammonia; someconvert it to nitrate, which is highly mobile in water. In soil,ammonia is also rapidly converted to ammonium ions.Ground Water: The amount of anhydrous ammonia typicallyrequired for methamphetamine synthesis is not likely to causesignificant ground watercontamination. However, if a largespill occurs, ground watercontamination may result.Surface Water: Plants andmicroorganisms rapidly take upammonia in water. Bacteriareadily convert ammonia tonitrate, creating a biochemicaloxygen demand several daysafter contamination. This can leadto depletion of dissolved oxygenand result in death to aquaticorganisms, but only if large spillsoccur and contamination is highly significant.Indoors: Long-term contamination of indoor surfaces byanhydrous ammonia is not a concern. If spilled, liquefiedanhydrous ammonia readily evaporates into the air. However,if sources of ammonia are present, such as with a leakingstorage tank or cylinder, ammonia vapors can pose animmediate health concern.

Chemical HazardsReactivity: Anhydrous ammonia reacts with strong oxidizers,acids, halogens, bleach, salts of silver, zinc, copper, and othermetals. It is corrosive to copper and galvanized surfaces.Flammability: Anhydrous ammonia is considerednonflammable; however, at very high concentrations in air [15-28% (150,000-280,000 ppm)], it will explode if ignited. Becauseof this, anhydrous ammonia should be treated as a flammablegas. Pressurized tanks of any kind may rupture if heated.Chemical Incompatibilities: Anhydrous ammonia isincompatible with acids, aldehydes, amides, halogens, metals,oxidizers, plastics, and sulfur.

Exposure LimitsOccupational Exposure Limits (NIOSH, OSHA, & ACGIH)Short-Term Exposure Limit (STEL or ST): 35 ppm (24 mg/m3)8-Hour Time Weighted Average (TWA): 25 ppm (17 mg/m3)Immediately Dangerous (IDLH): 300 ppm

Preliminary Remediation Goals (PRGs)(U.S. EPA, Reg. 9):Air: 0.14 ppm (0.1 mg/m3)Soil & Water: not available

More Information

Frostb

iteFrostbite

Authors: Karlyn Black Kaley, PhD, DABT & Charles Salocks, PhD, DABT • Graphic Design: Karlyn Black Kaley, PhD, DABT

Office of Environmental HealthHazard Assessment (OEHHA)

www.OEHHA.CA.Gov

Department of ToxicSubstances Control (DTSC)

www.DTSC.CA.Gov

OEHHA


IodineRecognizing Iodine

September 2003


Appearance: Laboratory grade elemental iodine appears aseither a fine, dark powder or as grayish-black to purple crystalsthat have a metallic luster. At room temperature iodine crystalsreadily vaporize to a violet-colored gas (Figure 1).Odor: Characteristically strong, sharp, biting, irritating odor.Note: Odor is not a good indicator of the presence of iodinevapors and does not provide reliable warning of hazardousconcentrations which occur at levels below odor detection.

Odor Threshold: 0.8 ppm (8 mg/m3)Odor Safety Class: D (only 10-50% of attentive persons candetect the threshold limit value concentration in air).Vapor Density: 8.8 (air = 1.0); iodine vapor is heavier than air,

and it may concentrate near the ground or in depressions.

Health HazardsInhalation Exposure: Iodine vapor causes eye, skin, noseand throat irritation, coughing, wheezing, and laryngitis.Exposure to high concentrations may result in airway spasm,chest tightness, breathing difficulty, severe inflammation, andfluid accumulation in the voice box, upper airways, and lungs.Some people develop allergic hypersensitivity to iodine vapor.Ingestion (Oral) Exposure: Iodine crystals, powder, andconcentrated solutions can cause burns in the mouth and throat.Ingestion may cause vomiting, abdominal pain, and diarrhea.Severe poisoning may result in headache, delirium, or a dropin blood pressure. Ingestion of 2-4 grams of solid iodine canbe fatal for an average adult.Skin (Dermal) Contact: Burns, irritation, tissue damage, andskin rash result from contact with concentrated iodine. Diluteantiseptic solutions are low in toxicity, but in some cases contactresults in a sensitization reaction that includes fever, skineruptions, and rash. Iodine can be absorbed slightly through

the skin and enter the blood.Eye Contact: Concentrated iodinevapor causes brown staining andcornea cell damage. The thresholdfor eye irritation is about 0.2 ppm (2mg/m3), which is much lower than theodor detection threshold. Diluteiodine solutions produce pain,inflammation, and can damagetissues.Chronic Effects: Effects of long-termexposure to iodine vapor in humansare not known. Iodide is an essentialmicronutrient in the diet. It is requiredin small amounts for normal functionof the thyroid gland. In laboratoryanimals, long-term inhalation of iodinevapors disrupts thyroid function and

reduces the ability of the lungs to take up oxygen. Chronicingestion of amounts that exceed dietary requirements causeshealth problems such as dietary iodism and goiter.

Commercial Products: Pure iodine crystals in brown glassbottles can be obtained from chemical supply houses.Veterinary iodine solutions, used asantiseptics, are packaged in opaqueplastic bottles. Iodine may beobtained by mild heating of its salts(e.g. sodium iodide or potassiumiodide). Iodine crystals may also beobtained from iodine solutions by theaddition of 30% hydrogen peroxide.Pharmaceutical Iodine Solutions:These are typically dilute solutionsthat are brown in color. Official USPTincture is a topical antisepticsolution made up of 2% iodine and2.4% sodium iodide in 50% ethanol.Lugol’s Solution is stronger, made

up of 5% iodine and 10%potassium iodide in water.

Role in Drug SynthesisIodine is used to make hydriodic acid (HI) in the RedPhosphorus/HI methamphetamine synthesis method.

Vol. 1, No. 2: Clandestine Drug Labs/ Methamphetamine

Figure 1: Pure iodine crystals, heated slightly, showing somesolid iodine escaping directly to the air as obvious violet-colored vapors. Because of this “sublimation” property,exposures include dermal contact with solid crystals andinhalation of vapors which may not be quite as visible as thisat room temperature. Photographer, Charles Salocks.

Clandestine Labs/ Methamphetamine: IodineIodineIodineIodineIodineFirst Aid

Inhalation Exposure: Move to fresh air. Administer oxygenif needed. If breathing difficulty occurs, get medical attention.Contact with Clothing or Skin: Remove contaminatedclothing. Flush exposed skin and hair with water for at least 5minutes, and thoroughly wash when possible. Seek medicalhelp if needed.Contact with Eyes: Flush eyes with water or saline solution forat least 15 minutes. Remove contact lenses if easily removable.Seek medical help immediately.

Ingestion Exposure: Do notinduce vomiting and do notadminister activated charcoal. Donot perform gastric lavage and donot attempt neutralization. If victimis conscious, rinse mouth withwater. Seek immediate medicalattention.Special Concerns for Children:Children may inhale relativelylarger amounts of iodinevapors due to their larger lungsize to body weight ratio and

increased respiratory rates.Children and others of short stature may receive higher doses,because iodine vapors are heavier than air and mayconcentrate near the ground in their breathing zone.

Handling & Safety

Environmental ConcernsAir: No information found.Soil: No information found.Ground Water: Contamination of ground water by iodine isunlikely since iodine (I2) is rapidly converted to iodide (I-) in thepresence of organic materials. Iodide has low toxicity and, insmall quantities, is an essential constituent in the human diet.Surface Water: Naturally occurring background concentrationsof iodine detected in surface waters range from 4 to 336 µg/liter. Iodine is hydrolyzed to iodate (IO3

-) and reduced to iodide(I-) ions in water. Iodine in drinkingwater contributes a small amountof the total daily intake. Therecommended daily intake is 150µg. Iodine toxicity is unlikely toresult from drinking water unlessthe water source is highlycontaminated. Studies of iodine’stoxicity to non-mammalianspecies were not identified. TheSuggested No AdverseResponse Level (SNARL) foriodide (I-) in drinking water is1.2 ppm (1.2 mg/liter).Indoors: Long-term contamination of indoor surfaces is notexpected. Elemental iodine has a vapor pressure of 0.3 mmHg at 25° C and readily volatilizes at room temperature. Ifpresent on indoor surfaces, iodine will be removed throughvolatilization. Inhalation exposure could occur under thesecircumstances. No standards for cleanup of indoor surfaceiodine contamination were identified.

Chemical HazardsReactivity: Iodine is an oxidizer and is highly reactive.Flammability: Iodine is not flammable. However, it is a strongoxidizer and supports combustion vigorously.Chemical Incompatibilities: Iodine is incompatible withaqueous and gaseous ammonia, powdered aluminum, andactive metals such as lithium, sodium, and potassium. Violentexplosions may occur when mixed with acetaldehyde oracetylene gas. Large quantities of iodine may react withantimony, producing heat, flame, and explosion.

Exposure LimitsOccupational Exposure Limits (NIOSH, OSHA, & ACGIH))Ceiling Limit: 0.1 ppm (1 mg/m3)Immediately Dangerous (IDLH): 2 ppm (21 mg/m3)

Preliminary Remediation Goals (PRGs), (U.S. EPA, Reg 9):Air, Soil & Water: not available

More Information



www.OEHHA.CA.Gov


www.DTSC.CA.Gov

OEHHA


General: Little information on the toxicity of elemental lithiumis available. The greatest health concerns regarding lithiummetal come from exposure to lithium hydroxide (LiOH); a strong,highly corrosive base formed when lithium reacts with water.Inhalation Exposure: Since lithium metal is not volatile,inhalation is not typically a significant route of exposure forlithium metal. However, if finely divided lithium particles wereinhaled, serious injury to the nasal passages, upper airways,and lungs due to formation of LiOH could result. Respiratorydistress syndrome has been reported in cases of severeexposure resulting in shortness of breath, rapid breathing, and

low arterial blood oxygen.Skin (Dermal) Exposure:Dermal uptake of lithium is notlikely to be a significant routeof exposure. Absorption ofsolid lithium across the skinis poor, although contact withfinely divided lithium or lithiumpowder might present ahazard because these forms

may react with skin moisture to form corrosive LiOH.Eye Contact: Exposure to lithium particles may result in seriouseye injury due to the formation of highly corrosive LiOH.Ingestion: In large amounts, lithium would primarily affect thegastrointestinal (GI) tract, the central nervous system (CNS),and the kidneys. Acute GI effects include abdominal pain,

nausea, vomiting, and diarrhea. CNSeffects include tremors, loss of musclecoordination, muscle rigidity, lethargy,and exaggerated reflexes. Sedation,mental confusion, agitation, seizures,and coma may occur at high doses.Symptoms associated with kidney

toxicity are an initial increase in urine output, subsequentelevation in blood non-protein nitrogen, and finally, diminishedurine output. Other potential adverse effects include cardiacarrhythmias, low blood pressure, and kidney toxicity.

LithiumRecognizing Lithium

September 2003

Commercial: Lithium metal in the form of ribbon, wire,rod, ingot, granules, powder, or shot can bepurchased from chemical supply houses.Rechargeable and non-rechargeable lithium

batteries are frequently used to obtain elementallithium for us in theillegal synthesis ofmethamphetamine(Figure 1, A & B).Pharmaceutical:Lithium forpharmaceutical usecontains lithiumcarbonate or lithiumcitrate, both of whichare salts ofelemental lithium, butlithium salts cannotbe used to make metallic lithium andare not used for illicit synthesis ofmethamphetamine.



Elemental lithium is used as acatalyst to synthesize methamphetamine from ephedrine

in the ammonia / alkali metal synthesis method commonlyreferred to as the “Nazi” method.

Appearance: Lithium is a soft, silvery-white metal that becomesyellowish upon exposure to moist air. It is soluble in liquidammonia, producing a blue solution.Odor & Odor Threshold: Not applicable. Lithium metal isodorless.Vapor Density: Not applicable. Lithium is not volatile.Odor Safety Class: Not applicable. Lithium is odorless.Therefore, odor provides no warning of hazard.

Health HazardsVol. 1, No. 4: Clandestine Drug Labs/ Methamphetamine

B

A

[1][2]

Figure 1: Lithium is a light-weight silvery colored metalused to synthesize methamphetamine. It is collectedfrom camera batteries [A] and other small button typebatteries [B]. Once these batteries are broken open,the lithium [B.1.] immediately begins to react with air[B.2.]. Photographers, Charles Salocks and Caron Poole.

NH4

Clandestine Labs/ “Meth”: LithiumLithiumLithiumLithiumLithiumFirst Aid

Inhalation Exposure: Move to fresh air. If victim is notbreathing, give artificial respiration. If victim has difficultybreathing, give oxygen. Keep victim in a half upright position.Get medical attention immediately.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed skin and hair with waterfor at least 15 minutes. Thoroughly wash with soap and waterwhen possible. Seek medical attention if necessary.Contact with Eyes: Flush exposed eyes with water for at least

30 minutes. Remove contactlenses if possible. Seekimmediate medical attention.Ingestion (Oral) Exposure: Ifvictim is conscious, give 2-4 cupsof milk or water. Do not inducevomiting. Seek medical attention.Special Concerns for Children:Children may not recognize thedangers associated withchemical exposures. Theymay therefore be more

susceptible to accidental or purposeful exposures.

Handling & Safety

Environmental Concerns

General: Only small amounts of lithium are required forsynthesis of methamphetamine. For this reason, wastegenerated by a clandestine methamphetamine lab is unlikelyto result in significant lithium contamination of soil, surface water,or ground water.Soil: The earth’s crust naturally contains lithium with varyingconcentrations depending upon location. As noted above,contamination of soil is unlikely.Ground Water & Surface Water: No information available.Drinking Water: California statestandards for lithium compoundsin drinking water have not beenestablished.Indoors: Lithium surfaces maybecome coated with a mixture oflithium hydroxide, lithiumcarbonate, and lithium nitride.Lithium hydroxide is extremelycorrosive; however, since theamount of lithium used is small,the amount of lithium hydroxideformed will also be small.

Chemical HazardsReactivity: Lithium is less reactive than sodium and much lessreactive than potassium. Freshly cut surfaces tarnish in airdue to reaction with oxygen and nitrogen. Pieces of lithiummetal react slowly with water to liberate hydrogen, a flammablegas.Flammability: Lithium is a flammable solid. Finely dividedand powdered lithium metal may ignite in air at ambienttemperatures and reacts vigorously with water to form hydrogengas and a strong caustic solution of lithium hydroxide. Sincereaction with water may lead to spontaneous ignition, powderedor granular lithium should not be combined with water. If heatedto its melting point (357 ºF, or 181 ºC), lithium is likely to ignitespontaneously.Chemical Incompatibilities: Water and air.

Exposure LimitsOccupational Exposure Limits (NIOSH, OSHA & ACGIH)Short-Term (STEL): not established.Threshold Limit (TLV): not established.Immediately Dangerous (IDLH): not established.Preliminary Remediation Goals (PRGs):Air: not established.Soil: Residential: 1,600 ppm (1,600 mg/kg)

Industrial: 20,000 ppm (20,000 mg/kg)Water: 730 ppb (730µg/L)

More Information



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SodiumRecognizing Sodium

September 2003

Commercial: Sodium is available from commercial labsin the form of ingots, lumps, or sticks. It is packaged incontainers filled with mineral

spirits or kerosene, or packagedunder nitrogen. It is also sold as30-40% dispersions in toluene,mineral spirits, light oil, or paraffinwax. Operators of clandestine druglaboratories may produce“homemade” sodium by electrolysisof sodium hydroxide. The mostcommon commercial source ofsodium hydroxide is Red Devil lye(Figure 1, B.).Pharmaceutical:There are nop h a r m a c e u t i c a luses of elementalsodium.



Elemental sodium, an alkali metal, is used as a catalyst inthe anhydrous ammonia / alkali metal “Nazi” method ofmethamphetamine synthesis to convert the precursorephedrine or pseudoephedrine product to methamphetamine.

Appearance: Sodium is a soft, silvery, solid metal that canreadily be cut with a knife. Lustrous when freshly cut (Figure 1,A.1.), it rapidly tarnishes to a dull gray in air (Figure 1, A.2.).Sodium may develop an outer crust of sodium oxide, whichmay appear sponge-like. Sodium dissolves in liquid anhydrousammonia forming a blue solution. At higher concentrations,these solutions are copper colored and have a metallic luster.Odor & Odor Threshold: Not applicable. Sodium is odorless.Odor Safety Class: Not applicable. Sodium is odorless.Vapor Density: Not applicable. Sodium is not volatile.

Figure 1: Pure sodium is soft, silvery in color, and shinywhen first cut [A.1.]. Pure sodium rapidly forms a dull grayoxidation crust when exposed to air [A.2.]. Sodium metalcan be obtained from electrolysis of sodium hydroxidecontaining products like the drain cleaner shown here[B]. Photographers, Charles Salocks and Caron Poole.

Health HazardsGeneral: Sodium metal reacts with water to produce highlycaustic sodium hydroxide (NaOH), which can cause severechemical burns resulting in permanent damage to all biologicaltissues. Reaction of sodium with water also generates heatwhich may result in thermal burns. NaOH is effectivelyneutralized by contact with tissue and does not producesystemic toxicity. Short-term contact with small amounts ofsodium, followed by rapid recovery, is not likely to cause long-term effects.Inhalation Exposure: Inhalation of vapors is not a typical routeof exposure to solid sodium. Inhalation of finally divided solidparticles or liquid suspensions could produce burns in thenose, mouth, throat, and upper respiratory tract.Skin (Dermal) Exposure: Direct contact with sodium can causedeep, serious burns which appear soft and moist and are very

painful. Less severe exposures result ininflammation, redness, and swelling of theskin. Irritation may become apparent withinminutes of exposure. Fatalities haveoccurred following contact with finelydivided sodium dispersed in hydrocarbonsolvents such as mineral oil or toluene.

Eye Contact: Direct eye contact canresult in serious burns. Formation oflesions, destruction of cells andtissue, inflammation, andopacification of the cornea mayresult. Ulcerations may progress forseveral days following exposure.Potential effects include cataracts,glaucoma, adhesion of the eyelid tothe eye, blindness, and eye loss.

Ingestion: Once ingested, sodium will react vigorously withsaliva in the mouth and esophagus to produce severe chemicaland thermal burns of the mouth, esophagus, and stomach.Symptoms of serious injury to the esophagus includeconstricted airways, vomiting, drooling, and abdominal pain.


A

1

2

B

Clandestine Labs/ “Meth”: SodiumSodiumSodiumSodiumSodiumFirst Aid

General: If exposed to sodium metal, in general it iscritically important to seek medical attention immediately.Inhalation Exposure: Move to fresh air. If victim has difficultybreathing, give oxygen. If victim is not breathing, give artificialrespiration. Keep victim in a half upright position.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed areas with water for 15minutes or more and wash thoroughly when possible. Treat

burns as directed by medicalpersonnel.Contact with Eyes: Flushexposed eyes with water for atleast 15 minutes. Remove contactlenses if possible.Ingestion (Oral) Exposure: Donot induce vomiting. Consciousvictims should be given water.Special Concerns for Children:Toxic effects may be greatersince gastric acid in children

is not strong enough or present in great enough amountsto neutralize even small amounts of strongly alkalinecompounds. Children may not recognize the dangersassociated with chemical contact and may therefore be moresusceptible to accidental and/or purposeful exposures.Children may think pure sodium metal is food since it may beconfused with cream cheese or even chewing gum.

Handling & Safety

Environmental ConcernsGeneral: Elemental sodium reacts immediately with water anda number of organic compounds to form sodium hydroxide(NaOH) and hydrogen gas (H2). Unless it is protected fromcontact with moisture, sodium is unlikely to persist in theenvironment. Typically only small amounts of elemental sodiumare needed for methamphetamine synthesis. Wastes generatedby small scale clandestine methamphetamine labs are unlikelyto contain sufficient amounts of sodium to result in significantcontamination of air, soil, surface water, or ground water.Indoors: Sodium may form anouter layer of solid NaOH onsurfaces, which can remain veryreactive and hazardous. Becauseof the formation of NaOH,corrosion and destruction ofsurfaces may be apparent inareas where sodium was spilled.If accessible surfaces werecontaminated with sodium andresulting NaOH, potential routesof exposure include direct skincontact and ingestion resultingfrom hand-to-mouth activity.

Chemical HazardsReactivity: Sodium reacts violently with water, including moisturein the air, and dilute acids to form caustic NaOH and highlyflammable hydrogen gas. The reaction generates considerableheat, melting the sodium and frequently igniting the hydrogengas. Sodium reacts explosively with dilute sulfuric acid. It alsoreacts with organic compounds containing oxygen, nitrogen,sulfur, fluorine, chlorine and bromine, carboxyl, or hydroxylgroups. In general, finely divided sodium reacts much morequickly and more vigorously than large pieces of sodium.Flammability: Sodium ignites spontaneously if heated totemperatures above 120°C (250°F). Finely divided sodium mayignite at much lower temperatures. Since sodium melts at 98°C,transition from a solid to a liquid is an indication that sodium isapproaching its auto-ignition temperature. Combustion ofsodium produces sodium oxide smoke, which is hazardousand highly irritating.Chemical Incompatibilities: Water and organic compoundscontaining reactive groups noted above.

Exposure Limits

More Information

Occupational Exposure Limits (NIOSH, OSHA, & ACGIH)Short-Term Exposure Limit (STEL): not established8-Hr Time Weighted Average (TWA): not established10-Hr Time Weighted Average (TWA): not establishedImmediately Dangerous (IDLH): not establishedPreliminary Remediation Goals (PRGs) (U.S. EPA, Reg. 9):Air, Soil, & Water: not established

* If in finelydivided

powder form.

*


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RedPhosphorus

Recognizing “Red-P”September 2003

Commercial: Red-P is a component of matchbook strikeplates (Figure 1, B.). Clandestine methamphetamine lab

cooks may use scrapings from matchbook strikeplates as a source of Red-P. Red-P is available from

chemical supply houses (Figure 1, C.), but it is a U.S.Drug Enforcement Agency ListI chemical and sales aresubject to record keeping andreporting requirements.Red-P is also used inelectroluminescent coatings,in flame retardants forpolymers, in the production ofsafety matches, pyrotechnics,incendiary shells, smoke bombs, and tracer bullets; aswell as in the manufacture of fertilizers, pesticides, andsemiconductors. It is also used in organic synthesisreactions and in the manufacture of phosphoric acid,phosphine gas and other phosphorus-containing chemicals.Pharmaceutical: There are nopharmaceutical uses of Red-P.



Red phosphorus is combined with elemental iodine toproduce hydriodic acid (HI). HI is used to convertpseudoephedrine or ephedrine to methamphetamine.

Appearance: Red phosphorus (Red-P) is a solid at roomtemperature. It is found as crystalline or amorphous granules,or as pills or powder (Figure 1, A.). The color varies fromorange-red, to violet, dark red-purple, or dark reddish brown.Odor & Odor Threshold: Not applicable. Red-P is not volatile.It is odorless at room temperature.Odor Safety Class: Red-P is odorless. Note: Odorprovides no warning of hazard.

Health HazardsGeneral: Pure Red-P does not usually represent a significanthealth hazard. It is essentially non-volatile, insoluble in water,and poorly absorbed into the body. Red-P does react withwater vapor and oxygen in air to form extremely toxicphosphine gas, phosphorus oxyacids, white phosphorus, andphosphoric acid. Red-P may also be contaminated with whitephosphorus (White-P) and/or yellow phosphorus (Yellow-P),

which are toxic. Yellow-P is a formof White-P that contains impurities.Inhalation Exposure: Inhalation ofRed-P dust causes respiratory tractirritation, coughing, and bronchitis.If contaminated with White-P, it canalso cause liver or kidney damage.Skin (Dermal) Exposure:Prolonged and/or repeated contactwith Red-P may cause irritation ordermatitis. If White-P is present,

deep, slow healing chemical burns may result. If ignited,Red-P may cause thermal burns.Eye Contact: Red-P can produce eye irritation and corneal

injury. If White-P is present, severeirritation and burns may result.Ingestion: Pure Red-P isconsidered non-toxic. However, ifcontaminated with White-P, it maycause systemic poisoning.Systemic symptoms include a

garlic odor on the breath, irritation of thedigestive tract, stomach pains, vomiting,diarrhea, liver and kidney damage,anemia and other blood disorders, andcardiovascular effects, or death. Longterm ingestion of Red-P contaminated

with White-P may cause jaw bone degeneration (“phossy-jaw”).Special Concerns for Children: Children may not recognizethe chemical dangers and may be more susceptible toaccidental or purposeful exposures.


B

C

A

Figure 1: Red phosphorus is easily recognizable asa dark red to purple solid powder [A]. It can beobtained from scrapings off match box strike plates [B]and other incendiary products or from commercialchemical supply companies [C]. Photos Courtesy of CADepartment of Justice. Photographer, Charles Salocks.

NH4

Clandestine Labs/ “Meth”: RRRRRed Phosphored Phosphored Phosphored Phosphored PhosphorusususususFirst Aid

Inhalation Exposure: Move tofresh air. If victim has difficultybreathing, give oxygen; if notbreathing, give artificial respiration.Keep victim in a half uprightposition. Get medical attentionimmediately.Contact with Eyes: Flush eyeswith water for at least 15minutes. Get medical attention.

Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing and shoes. Flush exposed areas withwater for 15 minutes or more. Get medical attention.Ingestion (Oral) Exposure: Do not induce vomiting. If victim isconscious, give 2-4 cups of water or milk. Seek immediatemedical attention.

Handling & Safety

General: Red phosphorus will slowly degrade to highlytoxic phosphine gas (PH3) and phosphorus acids in theenvironment. Phosphine is reactive and usually undergoesrapid oxidation. The final products, phosphates, are harmless.In wastewater, Red-P will adsorb to sewage sludge. Redphosphorus is harmful to aquatic organisms.Indoors: If contamination occurs, Red-P would be expectedto persist. On indoor surfaces is would be found as a solidwhere spilled. Skin contact and ingestion resulting from hand-to-mouth activity could occur.

Chemical HazardsReactivity: Red-P reacts with water vapor and oxygen in air toform extremely toxic phosphine gas, phosphorus oxyacids,white phosphorus, and phosphoric acid. These reactions areaccelerated by higher temperatures or trace amounts of metals,including those found in household plumbing.Flammability: Red-P is a flammable solid and may pose amoderate explosion hazard by chemical reaction or on contactwith organic materials. Though stable, it is readily combustible.It will not ignite spontaneously, but may be ignited by heat,friction, static electrical spark, oxidizing agents, or physicalimpact. It may re-ignite after beingextinguished. The auto ignitiontemperature for Red-P is 260°C(500°F). At high temperatures,even in the absence of air, Red-Pcan burn, producing White-P.Chemical Incompatibilities: Red-P reacts with oxidizing agents,reducing agents, peroxides,strong alkalies (e.g., sodiumhydroxide or potassiumhydroxide), halogens, halides, andorganic matter. If it comes in contactwith oxidants (e.g., chlorine, fluorine,or bromine), Red-P may burn spontaneously or explode. Red-P reacts vigorously with cesium, lithium, potassium, rubidium,sodium, and sulfur. It explodes when combined with ammoniumnitrate and moist chlorates. Red-P is incompatible with metalsincluding aluminum and magnesium powders, beryllium,copper and copper containing alloys, manganese, metal oxides(copper oxide manganese dioxide, lead oxide, mercury (II)oxide, silver oxide, and chromium trioxide), metal peroxides(lead peroxide, potassium peroxide, and sodium peroxide),and metal sulfates (barium sulfate and calcium sulfate). Redphosphorus is also incompatible with nitric acid.Conditions to Avoid: Avoid light, ignition sources, dustgeneration, excess heat, oxidizers, flammable materials, friction,and physical impact. Under wet alkaline conditions, redphosphorus slowly releases phosphine gas, which is highlytoxic and highly flammable.

Exposure Limits

More Information

Occupational Exposure Limits (NIOSH, OSHA, & ACGIH):not established.

Preliminary Remediation Goals (PRGs)(U.S. EPA, Reg. 9): Air, Soil & Water: not established

First Aid



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ColemanFuel

Recognizing Coleman FuelSeptember 2003

Coleman Fuel represents a class of commercially availablepetroleum-based products that are often marketed underthe following names:

Amsol 10, Kensol 10, WhiteGas, VM&P Naphtha, OzarkTrail , Camp Fuel, andColeman Fuel . Theseproducts are complexmixtures of light hydrotreatedpetroleum distillatescontaining up to 25% n-hexane, 15% cyclohexane,and less than 0.001% benzeneby weight. Light hydrotreatedpetroleum distillates aretypically packaged in metalcans (Figure 1, A & B) but may also befound in chemically resistant plasticbottles or jugs.



Coleman Fuel and other lighthydrotreated petroleum distillatesare petroleum-based, nonpolar solvents, which are used

in the Hydriodic Acid/Red Phosphorus, Nazi and othermethods of methamphetamine synthesis to extractmethamphetamine base from the reaction solution.

Synonyms: petroleum ether, petroleum naphtha, lighthydrotreated petroleum distillates, white gas, Amsol 10, Kensol10, VM&P (varnish makers & painters) naphtha, camp fuel,and petroleum benzin.Appearance: Clear, colorless liquid.Odor: Similar to the odor of rubber cement.Odor Threshold and Odor Safety Class: Not available.Vapor Density: 3.0 (air = 1.0). Coleman Fuel vapors are heavierthan air. They may collect near the ground or in depressions.

Health HazardsGeneral: Coleman Fuel and petroleum distillates are acuteirritants that cause moderate burning, redness, and swelling ofbody tissues upon contact. Regardless of exposure route,these also act as central nervous system depressants causinglight-headedness, dizziness, nausea, headache, giddiness,loss of appetite, muscle weakness, impaired motor function,loss of coordination, blurred vision, and drowsiness.Inhalation Exposure: Inhalation of Coleman Fuel and otherpetroleum distillates may cause severe respiratory tract irritation,pulmonary edema (swelling and fluid build up), loss ofconsciousness, and suffocation. Potentially fatal chemicalpneumonitis can also result from aspiration of Coleman Fuelinto the lungs.Skin (Dermal) Exposure: Short-term contact results in mild

irritation. Long-term exposurecan result in chronic dermatitisand localized defatting of theskin. Systemic toxicity mayalso result from absorptionthrough the skin.Eye Contact: Direct contactmay result in burning, tearing,redness, and swelling. Ifuntreated, tissue damage mayresult.Ingestion: Ingestion ofColeman Fuel or other

petroleum distillates can cause burningand irritation in the mouth, esophagus,stomach, and intestines.Chronic Effects: Repeated exposureto Coleman Fuel and its constituents,such as n-hexane, over a period ofweeks to months can result in damage

to sensory and motor nerve cells. Effects include burning,numbness, or tingling in the feet, legs or hands, paralysis,and even permanent brain damage. Prolonged exposure mayalso damage the kidneys, liver, and respiratory system.


BA

Figure 1: Coleman Fuel [A], designed for use in campstoves, lanterns and heaters, is a petroleum-basedorganic solvent used to illegally synthesizemethamphetamine. Similar commercial camp fuelproducts are sold under different brand names such asOzark Trail [B]. These and other organic solvents arereadily found in hardware and sporting goods stores.Photos Courtesy of CA Department of Justice.

NH4

Clandestine Labs/ “Meth”: Coleman FuelColeman FuelColeman FuelColeman FuelColeman FuelFirst Aid

Inhalation Exposure: Move to fresh air. Administer oxygenif needed. If breathing difficulty occurs, get medical attention.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed skin and hair with waterfor at least 5 minutes, and wash with soap and water if possible.Seek medical attention if irritation or rash appears.Contact with Eyes: Flush exposed eyes with water for at least15 minutes. Remove contact lenses if possible. Seek

immediate medical attention.Ingestion (Oral) Exposure: Donot induce vomiting. Seekimmediate medical attention. Ifvomiting occurs, keep headbelow hips to reduce chances ofaspiration into lungs.Special Concerns for Children:Children may inhale relativelylarger amounts of vapors due totheir faster respiratory ratesand greater lung size to bodyweight ratio. Children may

also receive higher doses due to theirshort stature since Coleman Fuel vapors, being heavier thanair, may concentrate near the ground.

Handling & Safety


No environmental data are available specifically for ColemanFuel. The following sections are based on petroleum ether.Air: In the atmosphere petroleum ether will exist primarily as avapor. It will be readily degraded by reaction with sunlight.Removal from the air may also occur through wet deposition.Soil: Petroleum ether readily evaporates from wet and drysoils and is expected to quickly biodegrade. Petroleum etherand Coleman Fuel are both complex hydrocarbon mixtures.Their adsorption to sediment andmobility within soil will vary basedon the estimated ability of theirchemical components to bind tocarbon in soil (Koc values of 81 to650). Chemicals with short chainstructures (5-6 carbon atoms) andlower molecular weights willmigrate more quickly through soilthan heavier compounds. Lightermolecules have greater potentialto contaminate groundwater.Surface Water: When releasedto water, petroleum ether isexpected to biodegrade as well as evaporate into air.Accumulation in aquatic organisms is not likely to be a concern.Ground Water: In cases of large spills, Coleman Fuel maymigrate down into the soil before it evaporates. There it maycontinue on to contaminate ground water sources.Indoors: Long-term contamination of indoor surfaces bypetroleum ether hydrocarbon mixtures is not a concern,because these light hydrocarbon chemicals quickly evaporate.

Chemical HazardsReactivity: Coleman Fuel is stable under normal conditionsbut can be an explosion hazard if fumes come in contact withignition sources, heat, or intense sunlight.Flammability: Coleman Fuel can form flammable mixtureswith air and flash at room temperature. The lower explosivelimit (LEL) for n-hexane is 1.2% (by volume, roomtemperature); the upper explosive limit (UEL) is 7.5%. Similarexplosive ranges have been reported for petroleum distillatesand Amsol 10. Coleman Fuel vapor is heavier than air. Vapormay travel considerable distances to a source of ignition andflash back.Chemical Incompatibilities: Strong oxidizers.

Exposure Limits

More Information

For Petroleum Distillates, Occupational Exposure Limits(NIOSH, OSHA, & ACGIH)Ceiling Limit (C) (15-minutes): 444 ppm (1800 mg/m3)8-Hr Time Weighted Average (TWA): 500 ppm (2000 mg/m3)10-Hr Time Weighted Average (TWA): 86 ppm (350 mg/m3)Immediately Dangerous (IDLH): 1100 ppm (4455 mg/m3)

Preliminary Remediation Goals (PRGs)(U.S. EPA, Reg. 9): Air, Soil, & Water: not established Office of Environmental Health

Hazard Assessment (OEHHA)www.OEHHA.CA.Gov


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OEHHA


Appearance: Phosphine is a colorless gas at roomtemperature.Odor: Disagreeable, garlic-like, or decaying fish odor whenfound in commercial products. Pure phosphine gas is odorless.Odor Threshold: Minimum: 0.03 ppm Average: 0.5 ppm.Odor Safety Class: D (only 10-50% of distracted individualsperceive warning of the permissible exposure level). Note:Odor is not a good indicator of the presence of phosphine vaporsand does not provide reliable warning of hazardous concentrationswhich occur at levels below odor detection.

Vapor Density: 1.2 (air = 1.0). Phosphine is slightly heavierthan air.

PhosphineRecognizing Phosphine

September 2003

Commercial: Aluminum and zincphosphide release phosphine gas whenexposed to moisture. Both products areused as rodenticides. Aluminumphosphide is also used as a grainfumigant. Commercial pesticidescontaining aluminum phosphide areCelphos, Phostoxin, and Quick Phos.Phosphine gas for air monitoringinstrument calibration is available fromchemical supply companies inpressurized containers.Pharmaceutical: There are nopharmaceutical uses of phosphine gas.



Phosphine gas is an unintended,undesirable, and potentially lethalby-product produced during themanufacture of methamphetamine

using the Hydriodic Acid/Red-Phosphorus method (Figure 1).

Health HazardsInhalation Exposure: Inhalation is the primary route of exposurefor phosphine gas. Effects from short-term exposure to highconcentrations (greater than 2 ppm) may result in severe lungirritation, cough, and chest tightness. Neurological effectsinclude dizziness, lethargy, convulsions, and coma; agitationand psychotic behavior are often present as well. Signs ofphosphine toxicity include rapid and/or irregular heart rate,low blood pressure, shock, nausea, abdominal pain, vomiting,diarrhea, and cardiac arrest. Most acute symptoms occur withinthe first few hours after exposure; however, the onset of liverand kidney toxicity and severe fluid accumulation in the lungs(pulmonary edema) may be delayed for up to 72 hours. Forthis reason, persons with known exposure to phosphine gasshould be hospitalized and observed for several days.Skin (Dermal) Exposure: Direct skin contact is not likely tobe a significant route of exposure for phosphine gas.

Eye Contact: Direct eye contact maycause irritation, tearing, pain, swelling, andsensitivity to light.Ingestion: If ingested, certain types ofwaste generated by clandestinemethamphetamine labs may result in therelease of phosphine gas in the stomach.Symptoms of chemicals that producephosphine internally when ingested aresimilar to those that occur following acuteinhalation of phosphine gas.Chronic Effects: Long-term exposure tolow concentrations (0.5 to 2 ppm) includeanemia, bronchitis, nausea, vomiting,abdominal pain, diarrhea, tremors, double

vision, impaired gait, and difficultyspeaking. Liver and kidneydamage, structural changes inchromosomes of peripheralblood cells, and chemical-induced asthma may also occur.


Figure 1: Photo of a heat-resistant vessel containing ahydriodic acid / red phosphorus methamphetaminesynthesis reaction mixture. Phosphine gas is an unwantedpotentially lethal by-product generated during the synthesis.Phosphine may be present in the air space above the liquidreaction mixture. Photo Courtesy of CA Department of Justice.

NH4

Clandestine Labs/ “Meth”: PhosphinePhosphinePhosphinePhosphinePhosphineFirst Aid

General: People have died from exposure to phosphinegas at methamphetamine labs. There is no specific antidotefor this chemical. Medical treatment is generally supportive.Inhalation Exposure: Move to fresh air. If victim has difficultybreathing, give oxygen. If victim is not breathing, give artificialrespiration. Get medical attention immediately.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed skin and hair with waterfor at least 15 minutes. Thoroughly wash with soap and water

when possible. Get medicalattention immediately.Contact with Eyes: Flush eyeswith water for at least 30 minutes.Get medical attention immediately.Ingestion (Oral) Exposure: Donot induce vomiting. Seekimmediate medical attention.Special Concerns for Children:Children may inhale relativelylarger amounts of phosphinegas due to their faster

respiratory rates and greater lung size to body weight ratio.Children may also receive higher doses due to their shortstature. Phosphine is slightly heavier than air and may settleclose to the ground in the breathing zone typical for children.

Handling & Safety


Chemical HazardsReactivity: Phosphine combines violently with oxygen andhalogenated compounds. Phosphine also reacts with copper,silver, gold, and salts of these metals as well as with air,oxidizers, chlorine, acids, and moisture.Flammability: NFPA flammability rating = 4 (very flammable).The lower explosive limit in air = 1.8 % (26 g/m3). Phosphineis very flammable and potentially explosive. It may ignitespontaneously on contact with air.Chemical Incompatibilities: Phosphine reacts with air andmoisture along with copper, halogenated hydrocarbons,chlorine, oxidizers, and acids.

Exposure Limits

More Information

Occupational Exposure Limits (NIOSH, OSHA, & ACGIH)Short-Term Exposure Limit (STEL): 1 ppm (1.4 mg/m3)8-Hr Time Weighted Average (TWA): 0.3 ppm (0.4 mg/m3)10-Hr Time Weighted Average (TWA): 0.3 ppm (0.4 mg/m3)Immediately Dangerous (IDLH): 50 ppmPreliminary Remediation Goals (PRGs)(U.S. EPA, Reg. 9):Air: 0.31 µg/m3

Soil, residential: 18 mg/kgSoil, industrial: 180 mg/kgTap Water: 11 µg/m3

Air: Phosphine is extremely volatile. It is found as a gas atroom temperature and will readily disperse in the atmosphere.Any residue of phosphine present in or generated by solid orliquid waste should quickly disperse in the air.Soil and Water: Large amounts of buried phosphorus-containing waste may generate phosphine gas in large enoughquantities to present a significant source of soil and groundwater contamination. However, the amount of phosphine gasproduced by a typical clandestine laboratory does not representa significant threat to soil or groundwater. Due to its extreme volatility,any release of phosphine tosurface water would quicklyevaporate to the surrounding air.Indoors: Phosphine will not likelyaccumulate on indoor surfaces butmay be present as a gas in indoorenvironments.Natural Occurrence: Phosphineis formed in small amounts fromthe putrefaction of organic matter.Detection of low concentrations ofphosphine in drains, sewers, or septic systems would not beunexpected and should be noted if found.



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SodiumHydroxide

Recognizing “NaOH”September 2003

Commercial: NaOH is one ofseveral alkaline materials

referred to as “lye”. It is alsopackaged as caustic soda or sodalye. Commercial products in solidform include Red Devil Lye andDrano drain opener (Figure 1, A &B), while liquids include Easy Offoven cleaner and Liquid-Plummer

drain opener. Concentrated solutionsof sodium hydroxide in water areavailable from commercial chemicalsupply companies.Pharmaceutical: There are nopharmaceutical uses of sodiumhydroxide.



Sodium hydroxide is used to makesodium, an alkali metal that functionsas a catalyst in the anhydrousammonia/ alkali metal (“Nazi”) method. NaOH is also used

in a number of synthesis methods to raise the pH ofmethamphetamine reaction solutions.

Appearance: Sodium hydroxide (NaOH) is found as solid whitegranules, chips, or pellets. Solid forms rapidly absorb watervapor from the air. This process generates heat and results inthe formation of concentrated solutions of NaOH. Concentratedsolutions of NaOH in water are clear in color.Odor & Odor Threshold: Not applicable. NaOH is not volatileand is odorless at room temperature.Odor Safety Class: NaOH is odorless. Note: Odor providesno warning of hazard. Irritation of the nose and throat providesan indication of exposure to a concentration of dust, or fumesif heated, that is sufficient to produce initial symptoms of toxicity.

Figure 1: Commercial drain openers such as RedDevil Lye [A] and Drano [B] contain sodiumhydroxide which can be used in the illegal synthesis ofmethamphetamine. Photographers, Charles Salocks andCaron Poole.

Health HazardsGeneral: NaOH is highly corrosive. It is a powerful irritant byall routes of exposure. Low level exposure causes irritation,burning, and inflammation of the skin, eyes, nose, throat,windpipe and lungs. Higher level exposure causes severeburns resulting in permanent damage to all tissue it contacts.The mechanism of damage is two-fold: 1) thermal burns resultfrom heat generated when NaOH combines with moisture inthe body, and 2) chemical burns result from reaction with organicmolecules. NaOH produces damage on contact, often veryquickly; but, it does not go on to cause systemic toxicity, i.e.,damage other places in the body.

Inhalation Exposure: Acute, highconcentration exposures causesevere burns, swelling of the voice-box, lung edema (accumulation offluid), and irreversible obstructivepulmonary disease. Long-term lowerlevel exposure can result in chestpains, shortness of breath, ulcerationof the nasal passages, persistenthoarseness, and reactive airwaydysfunction syndrome (RADS), achemical-induced asthma.Skin Exposure: Concentrated NaOHcauses deep, serious, painful, soft,and moist burns. Dilute solutions maynot produce pain initially but can resultin serious burns if allowed to remain

on the skin. Chronic effects include dermatitis.Eye Contact: Tissue damage, inflammation, and opacification

of the cornea may occur. Cataracts,glaucoma, adhesion of the lid to theeye, eye loss, and blindness mayresult. Damage may progress for 72hours or more following exposure.

Ingestion: Severe injury to the mouth, esophagus, andstomach may result. Symptoms of injury include vomiting,drooling, pain, rapid and feeble pulse, collapse, and shock.


A

B

NH4

Clandestine Labs/ “Meth”: Sodium HySodium HySodium HySodium HySodium HydrdrdrdrdroooooxidexidexidexidexideFirst Aid

Inhalation Exposure: Move to fresh air. If victim hasdifficulty breathing, give oxygen. If not breathing, giveartificial respiration. Keep victim in a half upright position. Getmedical attention immediately.Contact with Clothing or Skin (Dermal Exposure): Rapiddecontamination is critical. Remove contaminated clothingand shoes. Flush exposed skin and hair with water for 15minutes or more. Get medical attention.Contact with Eyes: Flush eyes with water for at least 15 minutes.

Get medical attention immediately.Ingestion (Oral) Exposure: Donot induce vomiting. If victim isconscious, give 4-8 ounces wateror milk. Do not administeractivated charcoal or attempt toneutralize. Seek immediatemedical attention.Special Concerns for Children:Stomach acid in children maynot be not strong enough orpresent in great enough

amounts to neutralize even small amounts of NaOH. Therefore,toxic effects in children may be greater. The behavior patternsof children may also result in more frequent contact withcontaminated surfaces.

Handling & Safety

Environmental ConcernsGeneral: As a contaminant in surface water, NaOH would beexpected to raise the pH. NaOH is highly reactive and is rapidlyneutralized by organic chemicals in soil. For this reason, it isnot expected to significantly contaminate ground water or soil.Sodium hydroxide in air is subject to wet deposition (washoutby rainfall) and dry deposition. NaOH readily combines withwater vapor. The resulting aerosol or mist is corrosive.Indoors: Sodium hydroxide may be found as a solid or aconcentrated liquid on indoor surfaces. Solid forms may slowly“melt” by absorbing water vaporfrom air, forming a highlyconcentrated solution. Ifcontamination occurs, NaOHwould be expected to persist.The persistence of solid or liquidresidues will depend on the natureof the surface and to what degreeit is porous. Skin contact andingestion resulting from hand-to-mouth activity could occur. Clean-up standards for NaOH onsurfaces have not beenestablished.

Chemical HazardsReactivity: Mixed with water, solid forms and concentratedsolutions (>40%) of NaOH may generate enough heat to ignitecombustible materials. NaOH reacts with all mineral and organicacids, forming the corresponding salts. The heat generatedmay be sufficient to raise the temperature of liquids above theboiling point. This could result in sporadic, dangerous“bumping” of solutions. NaOH reacts with metals, such asaluminum, tin, and zinc generating flammable hydrogen gas.Flammability: Sodium hydroxide is noncombustible. However,if solid NaOH is mixed with water or acid it may generate enoughheat to ignite combustible materials.Chemical Incompatibilities: Sodium hydroxide is corrosiveto most metals. Sodium hydroxide is incompatible with acids,halogenated organic compounds, and nitromethane. MixingNaOH with acid may generate substantial heat. Reaction withtrichloroethylene (TCE) spontaneously forms dichloroacetylene,which is flammable. Reaction with metals, such as aluminum,tin, and zinc generates flammable hydrogen gas.

Exposure Limits

More Information

Occupational Exposure Limits (NIOSH, OSHA, & ACGIH)Ceiling Limit (C): 2 mg/m3

Short-Term Exposure Limit (STEL): not established8-Hr Time Weighted Average (TWA): 2 mg/m3

10-Hr Time Weighted Average (TWA): not establishedImmediately Dangerous (IDLH): 10 mg/m3

Preliminary Remediation Goals (PRGs)(U.S. EPA, Reg. 9): Air, Soil, & Water: not established


www.OEHHA.CA.Gov


www.DTSC.CA.Gov


OEHHA


HydrogenChloride

Recognizing “HCl”Februaruy 2004



HCl is used to produce the solid hydrochloride salt ofmethamphetamine. Both aqueous and gaseous forms can beused, but HCl gas is more effective.

Appearance: Anhydrous hydrogen chloride (HCl) gas iscolorless to slightly yellow at room temperature. When exposedto air, HCl gas condenses with moisture in the air to producedense, white, and corrosive hydrochloric acid vapors.Hydrochloric acid is a colorless orslightly yellow fuming, aqueous liquidformed by dissolving HCl gas inwater. Yellowing is caused by traceamounts of iron, chlorine, or organicmatter impurities.Odor: Pungent. Immediately irritatingat 5 ppm (7.5 mg/m3).

Odor Threshold: 0.26 ppm(0.4 mg/m3).Odor Safety Class: C (less than

50% of distracted individualsperceive warning of threshold limit).Vapor Density: 1.3 (air =1.0).Hydrogen chloride gas is heavier than air and may accumulateclose to the ground or in depressions.

Health HazardsGeneral: HCl is severely corrosive and irritating to all bodytissues. Prolonged exposure may cause permanent effects.Inhalation Exposure: HCl gas causes burning and irritation ofthe nose and throat, coughing, choking, sneezing, breathing

difficulty, chest pain, and headache. Inhalationof anhydrous HCl gas can be fatal if exposureto concentrations of 0.1% in air occur evenfor a few minutes. Exposure to highconcentrations of liquid or gaseous HCl canresult in constriction of the airways, swelling,fluid build up and tissue death in the lungs,rapid breathing and pulse, shock, decreasedblood pressure, tooth discoloration, gum andnosebleeds. HCl vapor is heavier than air.Asphyxiation might occur in confined,

un-ventilated areas.Skin (Dermal) Exposure: Directcontact with fumes or liquid cancause corrosive burns. Irritation,pain, inflammation, and ulcerationcan result. Frostbite may occur withexposure to anhydrous HCl as it isreleased from tanks.Eye Contact: Fumes can causeextreme irritation. Contact with liquidHCl can result in pain, swelling,corneal erosion, tissue death, and

may cause permanent eye damage.Ingestion: HCl ingestion can cause pain,irritation, nausea, vomiting, thirst, difficultyswallowing, salivation, corrosive burns,ulceration, and perforation of thegastrointestinal tract, which can be fatal.

Other effects include chills, fever, and kidney inflammation.Special Concerns for Children: Children may inhale largerdoses of HCl due to their greater lung size to body weightratio and increased inhalation rates. Short stature may also bea risk since vapors may concentrate near the ground.

Anhydrous HCl is a gas at room temperature but becomesliquid when put under pressure. Anhydrous (e.g. without water)HCl gas is typically stored and transported as a liquid inpressurized tanks (Figure 1, A). Aqueous solutions ofhydrogen chloride are calledhydrochloric or muriatic acid (Figure1, B). Hydrochloric acid is used as aningredient in toilet bowl cleaners. HClsolutions can also be purchased at poolsupply and hardware stores as an

acidifier, cleaner, and disinfectant.


A

B

Figure 1: Anhydrous hydrogen chloride gas is storedas a liquid in pressurized containers [A]. Aqueoussolutions of hydrogen chloride are called hydrochloricacid or muriatic acid [B] and are found in commercialchemical or swimming pool supply houses. Photos:Courtesy of CA Department of Justice.

NH4

Clandestine Labs/ “Meth”: HyHyHyHyHydrdrdrdrdrooooogggggen Chlorideen Chlorideen Chlorideen Chlorideen ChlorideFirst Aid

Inhalation Exposure: Remove affected person to freshair. Monitor for respiratory distress. Administer oxygen andassist ventilation as requried. Seek medical attentionimmediately. Severe respiratory tract irritation can progress topulmonary edema, the onset of which may be delayed up to24 to 72 hours after exposure.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed areas with water for at

least 5 minutes. Thoroughly washwith soap and water whenpossible. Seek medical attentionif needed.Contact with Eyes: Flushexposed eyes with water or salinesolution for at least 15 minutes.Remove contact lenses ifpossible. Seek immediatemedical attention.Ingestion (Oral) Exposure: Do notinduce vomiting, do not giveactivated charcoal, and do not

attempt to neutralize. Give 4-8 oz. of water or milk. Seekmedical attention.

Handling & Safety

Environmental ConcernsAir: HCl gas is subject to wet deposition (washout by rainfall).HCl gas readily combines with water in the air to form HCl acid.Soil: Anhydrous HCl gas readily combines with soil moistureto form HCl acid. HCl acid, an aqueous solution, can infiltratesoil and dissolve minerals, especially carbonates. This processtypically results in neutralization of the HCl acid. However, iflarge amounts of HCl acid are spilled, infiltration and downwardmigration through the soil column may occur.Ground Water: HCl acid canreadily move through soil spaceswhere it may come in contact with,and may acidify, ground water. Ifsignificantly neutralized by organicand mineral components in thesoil, or if diluted with sufficientamounts of water, ground watercontamination can be minimized.Surface Water: HCl dissociatesalmost completely in water to formacidic hydronium ions. Acifiedwater can be neutralized withagricultural lime (CaO), crushed limestone (CaCO3), or sodiumbicarbonate (NaHCO3).Indoors: Long-term contamination of indoor surfaces byanhydrous HCl is not likley a concern since it is a gas at roomtemperature and will typically dissipate. Care should be takennot to inhale HCl gas or vapors from HCl acid. If spilled onindoor surfaces, HCl acid can be neutralized by the addition ofcommon bases, such as sodium bicarbonate. Spills shouldbe addressed as recommended for hazardous materialscleanup of aqueous acids.

Chemical HazardsReactivity: HCl acid is highly corrosive and reacts with nearlyall metals. It reacts with oxidizers releasing chlorine gas. Whenmixed with water, it releases large amounts of heat.Flammability: HCl is not flammable, but in contact with strongbases (e.g., ammonium hydroxide or sodium hydroxide), anexplosive reaction can occur. Flammable hydrogen gas canbe produced when HCl contacts metals. Containers holdingHCl gas or hydrochloric acid may explode when heated andcorrosive HCl fumes may result. Water used to control a firemay become corrosive or toxic due to HCl acid contamination.Chemical Incompatibilities: HCl is incompatible with alkalis,amines, copper, copper alloys, hydroxides, zinc, sulfuric acid,and organic materials.

Exposure LimitsOccupational Exposure Limits (NIOSH & ACGIH)Ceiling Limit: 2 ppm8-Hr Time Weighted Average (TWA): not establishedImmediately Dangerous (IDLH): 50 ppm (75 mg/m3)Preliminary Remediation Goals (PRGs)(U.S. EPA, Reg. 9):Air: 14 ppb (21 µg/m3). Soil & Water: not established

More InformationOffice of Environmental HealthHazard Assessment (OEHHA)

www.OEHHA.CA.Gov


www.DTSC.CA.Gov


Frostb

iteFrostbite

OEHHA


Methamphetamine“Meth”

Recognizing “Meth”September 2003

Health HazardsRoutes of Exposure & General Effects: Meth-HCl can besmoked (inhaled), snorted, injected, or ingested. The route ofexposure primarily affects the rate of absorption and onset ofeffects. Injection and inhalation produce the most rapid effects.Meth is a central nervous system stimulant. Once absorbed itproduces the same physiological effects regardless of

exposure route.Acute Effects: Meth is irritating to skin, eyes,mucous membranes, and the upperrespiratory tract. Eye contact may cause pupildilation and retraction of the upper lid. Acuteintoxication can cause dizziness, headache,dry mouth, a metallic taste, anorexia, insomnia,

tremor, rash, chest pain,difficulty breathing, fainting,blurred vision, dilated pupils,impotence, bluish skin color,lung congestion, convulsions,and coma. Overdose maycause exaggeration ofreflexes, rapid breathing,

confusion, panic states, aggressiveness,hallucinations, brain oxygen loss, elevatedbody temperature, skeletal muscle wasting,fatigue, depression, acute paranoia, and aschizophrenic-like state. Other effects includenausea, vomiting, diarrhea, cramps, irregularheartbeat, high or low blood pressure, and

circulatory collapse.Chronic Effects: Long-termexposure may cause severeskin conditions, insomnia,irritability, poor concentration,

hyperactivity, personality changes, weight loss, teeth grindingand tooth loss, ulcers of the lips and tongue, physical andpsychological dependence, anxiety, fear, compulsive behavior,delirium, disorientation, hallucinations, or a psychoticschizophrenic-like condition with possible self-injury.

Appearance: The hydrochloride salt of methamphetamine(Meth-HCl) is a yellow or white crystalline powder. Street gradeMeth may occur in any number of colors depending on how itwas manufactured and what impurities exist in the final product.(Figure 1, A-D). Street Meth-HCl is also found as “Ice”, whichappears as bright clear crystals of high purity. The free baseof methamphetamine (Meth-base) is a yellowto brown liquid, which is soluble in organicsolvents (e.g., Coleman Fuel). Meth-baseliquid can be converted to Meth-HCl solid bybubbling hydrogen chloride gas through theMeth-base layer.

Chemical Forms: There are two isomericchemical forms ofmethamphetamine, d- and

l-Meth. The d- form is a potentcentral nervous system (CNS)stimulant. Meth produced byclandestine labs is usuallyfound as the d- isomer. l-Methhas little CNS activity and isused for the temporary relief of nasalcongestion.Pharmaceutical Products: l-Meth is found asthe active ingredient in over-the-counterproducts including Vicks Vapor Inhaler.When used as directed, l-Meth does notrepresent a significant healthhazard. d-Meth is acontrolled substance, DrugEnforcement Agency,Schedule II, but it is legallyavailable by prescription for

treatment of attention deficit disorder with hyperactivity andfor short-term treatment of obesity.Odor: Meth-HCl is odorless but has a bitter taste. Meth-

base has a sharp biting odor resembling geranium leaves.Meth-base is volatile at room temperature.


A

B C

DFigure 1: In the final synthesis stages, a methamphetamine-HCl slurry is oftendried in heat-resistant household or restaurant style glass dishes [A-C]. Thedrug is typically found as a solid cake or in broken chunks in these dishes. Streetgrade Meth varies greatly in color depending on the type and quality of thesynthesis method used [D]. Photos Courtesy of CA Department of Justice.

NH4

Clandestine Labs “Meth”: MethamphetamineMethamphetamineMethamphetamineMethamphetamineMethamphetamineFirst Aid

Inhalation Exposure: Move to fresh air. Give artificialrespiration if not breathing. If breathing difficulty occurs,give oxygen and seek medical attention.Contact with Clothing or Skin (Dermal Exposure): Removecontaminated clothing. Flush exposed skin and hair with waterfor at least 15 minutes. Thoroughly wash with soap and waterwhen possible. Methamphetamine can be absorbed throughthe skin. Seek medical attention if needed.

Contact with Eyes: Flush exposedeyes with water or saline solutionfor at least 15 minutes. Removecontact lenses if possible. Seekimmediate medical attention.Ingestion (Oral) Exposure:Contact the local poison controlcenter or a physician immediately.Wash out mouth with water ifperson is conscious. Do notmake an unconscious persondrink fluids or vomit. Ifvomiting does occur, keep

head lower than hips to helpprevent aspiration. If unconscious, turn person’s head to theside to help prevent aspiration.Special Concerns for Children: Meth-base is volatile andmay pose an inhalation hazard. Children may inhale relativelylarger amounts of vapors due to their faster respiratory ratesand greater lung size to body weight ratio. Meth-HCl found onsurfaces may be absorbed through the skin or inhaled as solid“dust” particles in the air. Long-term use of stimulants in childrencan cause growth suppression. Methamphetamine passes intobreast milk and can be detected in a breast-fed infant’s urine.

Handling & Safety

Environmental ConcernsAir & Soil: No information available.Ground Water & Surface Water: No information available.Indoors: Meth-base is volatile. Depending on environmentalconditions it may persist on indoor surfaces for several days.Meth-HCl is a stable solid and may persist on surfaces formonths or longer. Several states in the U.S. have developedclean-up standards for Meth contamination of indoor surfaces.These range from 0.1 to 5 µg Meth /100 cm2 surface area.None of these standards is basedon toxicity criteria or on estimatesof potential exposure that mightresult from contact with Meth-contaminated surfaces. If fundingwere provided, the CaliforniaEnvironmental ProtectionAgency’s Office of EnvironmentalHealth Hazard Assessment coulddevelop a risk-based advisorystandard for Meth residues onindoor surfaces and couldcontinue to evaluate fieldsampling and analysis methods formeasuring levels of methamphetamine contamination on indoorsurfaces and other areas around dwellings.

Chemical HazardsReactivity: Meth-HCl is stable at normal temperature andpressure.Flammability: Meth-HCl is a slight fire hazard. Dust in air mayignite or explode. Hazardous combustion or decompositionproducts include carbon monoxide, carbon dioxide, andnitrogen oxides. Combustion of meth-HCl may producehydrogen chloride gas.Chemical Incompatibilities: Strong oxidizing agents.

Exposure LimitsOccupational Exposure Limits (NIOSH, OSHA, & ACGIH)Ceiling Limit (C): not establishedShort-Term Exposure Limit (STEL or ST): not established8-Hr Time Weighted Average (TWA): not established10-Hr Time Weighted Average (TWA): not establishedImmediately Dangerous (IDLH): not established

Preliminary Remediation Goals (PRGs) (U.S. EPA, Reg. 9):Air, Soil & Water: not established

More Information



www.OEHHA.CA.Gov


www.DTSC.CA.Gov

IntroductionC

hemistry

Sam

pling & C

leanupR

egulationsS

acramento C

ounty

Sampling and Cleanup

What are we looking for?

Where are we going to sample?

Data research to determine on-site chemicals and location of activitiesLook for obvious stainingConsider dumping locations

Plumbing trapsSeptic systemsWaste pits

Use of real-time instruments, indicators

How much to sample?Follow local agency guidance!!Representative sampling

Every type of media in vicinityRandom samplingComposite sampling

Combine up to 4 samples of same type of material together

Wipe versus bulkQuality control

Cross-contamination: change gloves!!Field and Trip blanksPreservativesChain-of-custody

Methamphetamine Analytical Methods

No NIOSH approved method yet; to be published within 6 months (personal communication from NIOSH)Current Gas Chromatography Method used: USEPA SW 846, 8270d, “Semi-volatile Organic Compounds”Alternative: US Pharmacopia Method 621, HPLC-UV

General Wipe Sample Method (from NIOSH 9102, Elements on Wipes)

Labs

DataChem Labs, Salt Lake CityLC/MS, 0.05 μg/wipe sample$35/sample for 3 day TAT

Assay Technology, 800-833-1258 HPLC, 1 μg /ft2, 0.11 μg /100 cm2

$65/sample

EMSL, 800-220-3675 (Philadelphia, PA)Sample types

Bulk - Submit drywall, carpet, or ceiling tile samples (2 sq. in.)Wipe - Using sterile cotton gauze, wipe a 10 cm square areaVacuum Bag - Submit contents of vacuum bag (1-2grams)*

GC/MS, method 827075$/sample, 2-5 TATemail Scott Van Etten: [email protected]

Analytical Methods for other chemicals

Mercury: EPA 7471a, MercurySolid sampleAtomic Absorption

Lead: EPA 6010, Lead in Surface Wipes

ICP (0.001 μg/100 cm2)VOCs: EPA 5035, Volatile Organics

40 ml VOA vials w/teflon caps

Real-time Methods

Photoionizing detector for low ppm VOCsMercury vapor meterpH paperHaz-Cat kitsStarch spray to identify iodine contaminationOnly useful to help identify areas of probable contamination. Agencies will NOT accept these for clearance.

Micro-vacuumingBased on ASTM D5756-02: Standard Test Method for Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Mass ConcentrationUse high flow pump with glass fiber cassette, vacuum area

Analyze filter for methQualitative vs quantitative

Useful for sampling:Porous materials“soft” goods: carpet, drapes

Sampling StudiesNational Jewish Medical and Research Center, Colorado (John Martyny et. al.)

“Chemical Exposures associated with Clandestine Methamphetamine Laboratories”“Chemical Exposures associated with Clandestine Methamphetamine Laboratories using the Anhydrous Ammonia Method of Production”“Methamphetamine Contamination on Environmental Surfaces Caused by Simulated Smoking of Methamphetamine”“A 24-Hour Study to Investigate Chemical Exposures Associated with Clandestine Methamphetamine Laboratories”“Chemical Exposures Associated with Clandestine Methamphetamine Laboratories using the Hypophosphorous and Phosphorous Flake Method of Production”

Surface Methamphetamine Levels from various labs

430Living room Table450Return Air Vent520Floor790Kitchen Stove920Hotel Table1700Microwave1600Bath Exhaust Grill2400Microwave 2500Ceiling Fan2800Night Stand

μg/100cm2Location

ResultsAimed at law enforcementConsiderable sampling for meth during and after cooking processMeth emitted as a vapor primarily during “gassing out” phaseFound everywhere, not just in immediate vicinity of cookLevels up to 16 mg/cm2 found (usually much less)Can re-suspend meth, HCl and iodine by household activities

Sampling studies, cont.

Salt Lake Valley Health Department, Kevin M. Okleberry, MS, LEHSSampling data and examples

How Much Meth is Present?

Average meth level on surfaces in Utah labs prior to decontamination is 33,143 nanograms (ng) per 100 cm2 surface area; range is from 30 ng to 771,000 ng/100 cm2 (total of 18 properties sampled)Sampling before decontamination is not required under new regulations

How Much Meth is Left?

Average meth residue level after first decontamination is 2,389 ng/100 cm2, range is 10 ng to 59,000 ng/100 cm2

(total of 34 properties sampled)Additional decontamination often required to remove remaining residue

Average Levels of Meth Residue

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

Pre-Decon Post-Decon

ng meth per 100sq cm surfacearea

How Hazardous is It?Prescription dose of methamphetamine for ADHD is usually 20-25 mg (25,000 μg) daily.Using a dermal uptake equation and the 0.1 μg/cm2 cleanup level, a toxicologist from OEHHA calculated that an infant would have a daily uptake of 0.3 μg/day.Pre-decontamination levels of meth in some labs may approach or exceed prescription dosage, especially for children (adjusted for weight)No long-term studies of hazards of low-level exposure to methamphetamine residue

Typical Dosage AmountsA first time user will typically start with 1/8 gram.A regular user will typically start a “run” with a “quarter” (a quarter of a gram).On a 3 day run, an average user might use between 3 “quarters” (of a gram) to 1 gram or more.During a 3 day run, a regular injector will average 3-8 injections (depending on tolerance levels and how he/she chooses to divide the drug).The high from a “quarter” of meth will typically last between 6-8 hours (depending on tolerance & quality).

Case Studies of Actual Labs Decontaminated

Under Utah’s Regulation

Example Case #1

House that new owner suspected to be a meth lab, due to neighbor reportsNo contamination noted during initial assessmentIodine “bled” through paint months after initial inspection, new inspection of house 18 months later found extensive iodine staining

Results

Tests showed elevated levels of methamphetamine throughout houseHighest level was 56 μg/100 sq cm in room where staining was heaviestContractor completely gutted most of the house, due to extensive iodine staining

Conclusions

Iodine staining was most prevalent in basement laundry roomHumidity from washer may have helped “draw out” the iodine residue under the paintElevated meth residue levels were discovered at least 18 months after any cooking occurred

Case Example #2

Large house recently occupied by new ownersOwners received reports of drug manufacturing by previous ownersProperty was assessed by a listed contractor, some suspected iodine stains foundOwners had two different contractors sample property

Results

All four samples taken by contractors for testing were below the limit of 0.1 μg/100 sq cmSuspected stains were determined not to be iodine, no other obvious signs of contamination were noted

Conclusions

Owners completely cleaned the house prior to moving in; they may have unwittingly decontaminated the house at that time

Case Example #3Large lab was found in storage unit; unit measured about 10 ft by 30 ftPreliminary sample in unit revealed methamphetamine levels above 29,000 ngContractor who assessed property noticed a 2-inch gap between the walls and the ceiling and a tube placed in the gap on one sideHealth Department required sampling of adjacent units to determine extent of contamination

Gaps and Vent Tube

Results of First Round

Samples showed methamphetamine levels of over 10,000 ng and 9,000 ng in adjacent unitsThese units also had gaps in walls, raising possibility of contamination in adjacent unitsHealth Department required sampling of these units to determine contamination

Results of Second Round

All adjacent units had levels of methamphetamine significantly above the regulatory limitGaps were found in all walls in all the units, allowing any vapors from process to spread throughout the complexOwner will sample adjacent units

Layout of Storage Units

4,460 ng meth per 100 sq cm




Lab Site



1, 650 ng meth per 100 sq cm

Conclusions

Contamination was found several units not adjacent to the unit that was used as a labThe gaps between the walls and ceiling and the tube allowed the heated reaction vapor to spread to other unitsSampling is continuing at this time

Case Example #4Large, older house with basement and detached garageMother (owner) lived upstairs, adult children (meth cooks) lived downstairsLab was found in garage, lab equipment and glassware were found in a basement bathroomNo evidence of contamination was noted in upstairs portion of house

Lab Setup and Glassware

ResultsInvestigation revealed that mother was unaware of cooking in housePreliminary sample from upstairs kitchen was negative; downstairs samples all revealed significant contaminationHouse had a single heating system, samples were taken upstairs near ventsLow levels of contamination were found upstairs near the heating vents

Results of Preliminary Sampling

325 ng/

100 sq cm

Bathroom ceiling

29,611 ng/ 100 sq cm

Bathroom ceiling

692 ng/

100 sq cm

Computer room

1,375 ng/ 100 sq cm

Bedroom table

<100 ng/

100 sq cm

Kitchen stove top

17,494 ng/ 100 sq cm

Bedroom ceiling

Upstairs

Samples

Downstairs

Samples

Conclusions

Meth dust or vapor from the cooking process probably was circulated through the house by the furnace fanAffected areas upstairs were decontaminated as well as rooms in basement

Lessons LearnedMeth and iodine vapor can migrate throughout a structure, and significantly contaminate surfaces in rooms not used for cookingHigh levels of meth residue may be present without obvious signs of contaminationIodine can “bleed” through paint months or years after initial contaminationProper decontamination of property can remove almost all chemical residues

Sampling Studies, Cont.

Minnesota Dept. of Health/Pollution Control Agency study on meth deposition in building materials (Kate Gaynor & Steve Lee)Used to revise Clan Lab Cleanup Guidance

Mn ResultsMeth samples higher closer to ceiling than floorMeth samples always highest near the cooking areaMeth penetrates a variety of materials including upholsteryMicro-vacuuming gives better indication of presence of meth in porous surfaces than does wipe samplingSerial wiping of the same area only slightly reduces total concentration (much more absorbed into the material than wiped off)Meth samples on top of ceiling fan blades MUCH higher than nearby wipe results: dust on blades probably absorbs meth more easily

Mn Cleanup Guidance based on Risk Acceptance

No Residual: bulldoze house and completely rebuildMinimal acceptable risk:

Acceptable Residual Risk:

Cleanup MethodsDTSC Survey Results

WallsVisible contamination

Remove (71%), decontaminate, (43%),Repaint (29%)

No visible contaminationDecontaminate (57%), Repaint (43%)

FloorsCarpet: visible contamination

Remove (86%) or bleach (14%)

Carpet: no visible contaminationShampooed (57%), removed or treated with baking soda (20%) and “other” (14%)

Cleanup Methods, cont.Floors

Linoleum w/stainingRemoval (71%), wash (14%) or bleach (14%)

Linoleum w/o visible stainWash (71%), bleach or treat with baking soda (29%)

Hardwood w/stainingRemove (71%), wash (43%) or bleach/baking soda rinse (14%)

Hardwood w/o stainingWash (57%), bleach or baking soda rinse (14%), “other” (57%)

Encapsulation by paint or other sealersAfter multiple washings

Cleanup cont.HVAC system

Consider especially if serves multiple unitsReplace all filtersRemove vents and clean including surfaces near registers (supply and return)Consider cleaning ductworkAssess AC and furnace

Porous materials: disposeClothing, linens, draperies, upholstered furniture, carpeting, paper goods & books

Waste DisposalMunicipal landfill or hazardous waste

Effectiveness of Bleach in Cleanup

DTSC Study 2/2/04

Guidelines for Environmental Sampling at Illegal Drug Manufacturing Sites

Revised November 30, 2005

For more information: www.doh.wa.gov/ehp/ts/cdl.htm Clandestine Drug Lab Program Office of Environmental Health and Safety PO Box 47825 Olympia, WA 98504-7825 (360) 236-3381 (888) 586-9427 (Toll Free)

For persons with disabilities, this document is available on request in other formats. Please call 1-800-525-0127 (TTY/TDD 1-800-833-6388).

DOH Pub 334-106 09/2005

http://www.doh.wa.gov/ehp/ts/cdl.htm

Table of Contents I. GENERAL RECOMMENDATIONS: ...................................................................... 3

A. EQUIPMENT AND SUPPLIES................................................................................ 3 B. OFF-SITE SAMPLING PREPARATION.............................................................. 4 C. ON-SITE SAMPLING PROCEDURES................................................................. 5 D. FIELD QUALITY CONTROL (QC) ..................................................................... 5 E. CHAIN OF CUSTODY RECORD ......................................................................... 6 F. TRANSPORTATION OF SAMPLES .................................................................... 7 G. DECONTAMINATION PROCEDURE FOR EQUIPMENT/SUPPLIES............. 7 H. SITE CLEAN UP AND PERSONNEL DECONTAMINATION:.......................... 8 I. SAMPLE LOG FORM OR FIELD NOTEBOOK:.................................................. 8 J. HANDLING AND STORAGE OF METHANOL ................................................. 8

II. METHAMPHETAMINE WIPE SAMPLES ......................................................... 9 A. OFF-SITE SAMPLE PREPARATION ..................................................................... 9 B. ON-SITE SAMPLING PROCEDURE FOR SINGLE SURFACE (DISCRETE) WIPES............................................................................................................................. 9 C. ON-SITE SAMPLING PROCEDURE FOR COMPOSITE SURFACE WIPES11 D. FIELD QUALITY CONTROL................................................................................ 11

III. WASTEWATER SAMPLING............................................................................ 12 A. OFF-SITE SAMPLE PREPARATION ................................................................ 12 B. ON-SITE SAMPLING PROCEDURES............................................................... 12 C. FIELD QUALITY CONTROL............................................................................. 13

IV. COLLECTING SOIL SAMPLES......................................................................... 14 A. CONDUCT OFF-SITE SAMPLE PREPARATION............................................. 15 B. ON-SITE SAMPLING PROCEDURES................................................................ 15 C. FIELD QUALITY CONTROL:.............................................................................. 17

V. SAMPLING FOR CORROSIVES ......................................................................... 17 A. ON-SITE SAMPLING PROCEDURE................................................................. 17

VI. WATER SAMPLING ............................................................................................ 18 A. LAKES, STREAMS AND OTHER SURFACE WATER SAMPLES .................. 18

1. SAMPLING PROCEDURE .............................................................................. 18 B. SURFACE SLICK SAMPLES ............................................................................... 18

1. SAMPLING PROCEDURE ............................................................................. 18 C. WELL WATER SAMPLES ................................................................................... 18

1. SAMPLING PROCEDURE ............................................................................. 18 2. FIELD MEASUREMENTS ................................................................................ 19 3. SAMPLE COLLECTION.................................................................................... 20 4. Volatile Organic Compounds (VOC) ................................................................. 21 5. Other Organic Compounds, Metals, and Inorganics............................................ 22

REFERENCES................................................................................................................ 22 Rationale for the Establishment of the Washington State Department of Health’s Clandestine Drug Lab Program Decontamination Standards ..................................... 1

Guidelines for Environmental Sampling Page 3 at Illegal Drug Manufacturing Sites November 30, 2005

The following guidelines describe recommended procedures for collecting, handling, and transporting septic, soil, methamphetamine wipe, and caustic samples. Standard operating procedures (SOPs) are required to ensure collection of samples that are representative, accurate, and defensible. Modification of procedures may be acceptable and the guidelines are intended to allow flexibility. However, any deviation from the SOP outlined in these guidelines should be documented in the sampling plan as to the extent of and reason for the deviation. Deviations from the SOP should be pre-approved by local health staff before sampling is conducted. Sampling shall be conducted only by qualified personnel as defined in WAC 246-205-531(2)

“Collection of samples shall be performed by Department of Ecology staff; Department of Health certified CDL supervisors; or local health officers…”

I. GENERAL RECOMMENDATIONS:

A. EQUIPMENT AND SUPPLIES: OBJECTIVE: Equipment and supplies needed to conduct scientifically defensible environmental sampling.

Equipment Purchased from either a Certified Laboratory or Laboratory Supply Company:

Supplies Purchased from Retail Stores:

Filter papers Sample collection containers Analytical grade methanol Disposable templates Sludge judge Disposable plastic pipette Squeeze bottle pH Indicator paper Laboratory grade distilled water (ASTM Type II) Cooler Analytical Request/Chain of Custody form Chain of Custody seals

Field notebook Stainless steel spoon Large stainless steel container Disposable templates Disposable gloves Thumbtacks Masking tape Permanent ink marking pen Permanent ink ball-point pen Labels for collection containers 2 Equipment storage containers* Caddy Pre-moistened hand wipes Zip lock bags Ice or frozen ice packs** Camera Distilled water Paper towels Trash bags Person Protective Equipment (PPE) * One storage container for off-site and one for on-site.

** Must be able to maintain 4° C.


A. EQUIPMENT AND SUPPLIES (continued) 1. Use equipment from either a certified laboratory or a laboratory

supply company. Supplies can be purchase at retail stores, laboratory supply companies, and some analytical laboratories.

2. Equipment and supplies should be clean (sterilized if required) and in proper working condition before using.

3. Store equipment/supplies in a clean, secure storage container designated for only sampling media/supplies. Storage container is kept in a limited access area to avoid contamination and is never taken to a drug lab site.

a) Decontamination contractors are responsible for the safe custody of all sampling equipment from the time they receive it from the analytical laboratory until the time they use it and relinquish it back to the laboratory.

(1) Signed or initialed chain of custody seals should be maintained on appropriate equipment/supplies.

4. Store and transport sampling equipment/supplies separate from PPE and all other equipment used to decontaminate properties.

5. Use equipment/supplies only one time and properly dispose of them upon completion of the sampling project.

a) Exceptions to this rule exist and include supplies such as the caddy, “on-site“ equipment storage container and stainless steel tools, which may be reused after proper decontamination.

6. Whatman 40 filter paper is recommend, although the following have equivalent performance and can also be used; Whatman 41, 42, 43, 44, 540, 541, Ahlstrom 54, VWR 454 and S&S WH Medium.

7. Sample collection containers consist of standard laboratory 4-ounce containers and 40ml vials. All containers have Teflon-lined lids.

8. Templates should be thin (less than 3mm), capable of lying flat on a surface and stiff enough to maintain their shape. Area sampled is 100 cm2 (10cm by 10 cm) for single (discrete) samples, and four 25 cm2 (5 cm by 5 cm) areas for composite samples.

9. Gloves should be powderless.

B. OFF-SITE SAMPLING PREPARATION OBJECTIVE: To minimize contamination of sampling equipment and supplies and increase sampling efficiency while on-site.

1. Verify that the sampling plan has been pre-approved by the local health department. Sampling plan should include detailed descriptions of sampling techniques for each matrix being sampled (surface wipes, soil, surface water, drinking water, and septic tanks), sample location and type (single or composite).

2. Review approved sampling plan and determine what equipment/supplies are needed for the sampling project. Bring extras for unexpected occurrences and store them in the on-site storage container until needed. Note that the on-site storage and mailing containers are not brought into the contaminated/decontaminated area.

3. Conduct sampling preparation before going on site.


B. OFF-SITE SAMPLING PREPARATION (continued) 4. Lay out a disposable surface cover (such as a plastic tablecloth) in an

area free from contamination to use as your preparation site. 5. Put on gloves. 6. Pre-label sampling collection containers using permanent ink. Each

container must have a securely affixed label containing the following information.

a) Site ID--record the facility (ex. Use the address number) b) Sample ID--assign a number

7. Prepare a blank. (Note: For composite samples, the blank should consist of 4 filter papers).

8. Place sampling equipment and supplies needed for the sampling project into the on-site storage container.

C. ON-SITE SAMPLING PROCEDURES

OBJECTIVE: To collect representative samples in a consistent manner that can be replicated.

1. Eating, drinking, smoking, or other activities that may introduce contamination is prohibited during on-site sampling procedures.

2. Conduct sampling with two people; one person as the “Sampler,“ and the other person as the “Record Keeper.” It is recommended that both the “Sampler“ and the “Record Keeper“ meet the qualifications of WAC 246-205-531(2) and be certified CDL Supervisors.

3. Put on appropriate PPE. 4. Conduct a walk-through to ensure site is ready to sample. 5. Transfer equipment/supplies from on-site storage container to caddy.

Do not bring storage container into the contaminated area. 6. Continue with additional steps, outlined below, for on site sampling

procedures for methamphetamine, VOCs and caustics.

D. FIELD QUALITY CONTROL (QC) OBJECTIVE: To evaluate precision of the sampling process.

1. Field quality control (QC) samples typically consist of blank, duplicate and equipment rinsate samples. It is at the discretion of the local health staff to determine which QC samples are taken. Often staff will waive the collection of duplicates or rinsates for soils or septic sampling since, at the initial stage of investigation, sampling is being conducted to determine the presence of contamination only. Depending upon the initial sampling results, and at the discretion of local health staff, additional sampling, including QC samples, may be required.

2. MEDIA BLANK: A media blank is taken for methamphetamine wipe samples. The media blank is prepared off-site by the contractor and consists of placing a filter paper into a sample collection container, wetting it with methanol and tightly securing the lid. The container is carried on site, never opened and returned to the laboratory for analysis.


D. FIELD QUALITY CONTROL (QC) (continued) 3. FIELD DUPLICATE (REPLICATE): A field duplicate is an

independent sample that is collected at the same time and as close as possible to the sample it is replicating. The site environmental sample and the duplicate sample are taken separately from the same location or source, stored in separate containers, and analyzed independently.

a) Methamphetamine: Historically, duplicate wipe samples were collected as “back up” samples in case a sample container were to break during transport or for potential legal proceedings. However, since methamphetamine‘s holding time has not been established, duplicate samples are no longer taken for this purpose. If for some reason, duplicate meth wipe samples are taken, they are submitted to and stored by the analytical lab. Normally, CDL Contractors should not keep duplicates due to lack of ability to maintain conditions necessary to preserve sample integrity.

b) Methamphetamine: Duplicates are not taken to evaluate precision of sampling process due to the variability of sampling media (the non-uniform dispersion of methamphetamine residue).

4. EQUIPMENT RINSATE: An equipment rinsate consists of rinsing the sampling equipment with laboratory grade distilled water (ASTM Type II) after the equipment has been decontaminated and prior to sampling. The rinse water is collected and analyzed.

E. CHAIN OF CUSTODY RECORD

OBJECTIVE: To provide accountability for and documentation of sample integrity from the time the contractor receives sample equipment until the samples are transferred to a courier or analytical laboratory.

1. Use a custody record supplied by the analytical laboratory. 2. Chain of custody begins when contractor receives equipment from the

analytical laboratory or other supplier. The CDL contractor is responsible for the care and custody of sampling equipment. Chain of custody seals should be maintained on stored equipment. Each time a seal is broken, it shall be initialed, dated and recorded. A new custody seal is placed on remaining equipment being stored for future use.

3. The assigned field sampler is responsible for care and custody of samples from the time they are collected until they are properly transferred by signature to a courier or laboratory.

4. As few people as possible should handle samples. 5. Use permanent ink to enter the following information:

a) Project Name b) Sampling Site Address c) Sample Number (#125-1) (Do not put down location of the

sample) d) Sample Date (Date sample was taken)


E. CHAIN OF CUSTODY RECORD (continued) e) Sample Time (Time sample was taken) f) Sample Type (Single, composite) g) Sampled area (100 cm2)

(1) For Media Blank Sample: Record an area that is consistent with the area you typically sample and the number of wipes submitted with the media blank sample (100 cm2 wipe).

h) Analysis Requested (Methamphetamine, VOC) i) Field Notes (example: suspect high concentration in sample #

125-1, noted strong solvent odor) j) Number of Containers k) Report In: (Keep analytical results consistent with area

sampled. Since discrete and composite sample areas are currently both 100cm2, results would be reported in100 cm2).

l) Turnaround Time m) Signatures of sampling personnel n) Signatures of all personnel handling and receiving samples o) Date and Time samples received

F. TRANSPORTATION OF SAMPLES

OBJECTIVE: To preserve integrity of samples during transportation. 1. Place methamphetamine and VOC samples in a cooler, filled with ice,

immediately after collecting the sample. Temperature of 4ºC must be maintained.

2. Package containers in cooler in a manner that prevents breakage. 3. Complete analytical request and chain of custody form. 4. Place form inside a waterproof, zip lock bag and include it with the

mailing. 5. Attach chain of custody seal to outside of cooler.

a) Sign and date custody seal. 6. Deliver samples to analytical lab within 24 hrs of completing

sampling, by mail courier service or personal delivery. 7. Retain shipping receipts.

G. DECONTAMINATION PROCEDURE FOR EQUIPMENT/SUPPLIES

OBJECTIVE: To avoid cross contamination through proper decontamination of equipment and supplies.

1. Decontaminate using the following procedure: a) Wash the item thoroughly with soap and water. Recommended

soaps are Liquinox or Alconox. b) Rinse the item thoroughly with distilled water. c) Rinse stainless steel equipment with analytical grade methanol. d) Air dry. e) Wrap stainless steel supplies in aluminum foil.


H. SITE CLEAN UP AND PERSONNEL DECONTAMINATION: OBJECTIVE: To avoid cross contamination through proper waste disposal and personnel decontamination.

1. Dispose of used and unused sampling equipment into trash bags. a) Properly dispose of trash bags.

2. Remove PPE and dispose of in trash bags. 3. Decontaminate PPE that will be reused. 4. Store PPE separate from sampling equipment/supplies. 5. Wash hands with pre-moistened hand wipes or soap and water.

I. SAMPLE LOG FORM OR FIELD NOTEBOOK: OBJECTIVE: To sufficiently document field sampling activities to allow review of all aspects of sampling.

1. Document all field-sampling activities on a sample log form or in a bound all weather notebook with sequentially numbered pages.

2. New field notebooks are required for each sampling project to avoid cross contamination between projects.

3. Use permanent ink and record information in a legible manner. 4. Correct errors by drawing a single line through the error so it remains

legible, and adjacent to the error, have the responsible individual date and sign the correction.

5. Document any deviation from approved procedures in the sampling plan.

6. Maintain field book in an accessible location that protects it from damage and loss.

7. Record the following standard information in field notebook: a) Project Name b) Project Address c) Date of Project d) Name of personnel and tasks they performed e) Purpose of Project f) Arrival and Departure Times g) Field instruments used h) Instrument calibrations i) Sample Number j) Sample Location k) Surface Type l) Time each sample was taken m) Weather n) Pertinent conversations o) Sign each page

J. HANDLING AND STORAGE OF METHANOL

OBJECTIVE: To reduce risk of personal injury and cross contamination of methanol.

1. Methanol is a toxic and flammable liquid and must be handled and stored with all safety precautions related to toxic and flammable liquids.

2. Store small amounts of methanol and frequently replenish supply.


J. HANDLING AND STORAGE OF METHANOL (cont’d) 3. Place a signed or initial chain of custody seal over bottle top and

neck. 4. Inhalation of methanol vapors must be avoided. Containers must be

handled in a ventilated area. 5. Protective gloves should be worn when handling containers with

methanol. 6. Methanol should be stored away from open flames, areas of extreme

heat and other ignition sources.

II. METHAMPHETAMINE WIPE SAMPLES OBJECTIVE: Using methanol-moistened filter papers to collect wipe samples from hard, non-porous surfaces from areas of 100 cm² (10 cm x 10 cm) for single, discrete samples and 25 cm² (5 cm x 5 cm) for composite samples. Samples are taken from dry or relatively dry surfaces.

A. OFF-SITE SAMPLE PREPARATION

1. Follow steps described in “I-B” (OFF-SITE SAMPLING

PREPARATION), and continue as described below: 2. Remove lids from sample collection containers, placing them top

down on a contamination-free surface. 3. Put on clean pair of gloves. 4. Fold filter papers into quarters and place into sample collection

containers. Only one filter paper per container. 5. Saturate filter papers with methanol until wet but not dripping

(approximately 40 drops, or 2 milliliters). Excess methanol should be poured onto a paper towel and properly disposed of.

6. Secure lids tightly on containers and replace into shipping box. 7. Pre-label templates to match with labels on sample collection

containers. 8. Place other equipment/supplies in zip lock bags that are then placed

in the on-site storage container. Take only the equipment/supplies needed for the sampling job to the drug lab site.

9. Prepare sample log form/field notebook.

B. ON-SITE SAMPLING PROCEDURE FOR SINGLE SURFACE (DISCRETE) WIPES

1. Proceed to first sampling location;

a) Wash hands with pre-moistened hand wipes. b) Sampler and Record Keeper put on clean gloves.


B. ON-SITE SAMPLING PROCEDURE FOR SINGLE SURFACE (DISCRETE) WIPES (cont’d)

c) Record Keeper hands a template to the Sampler. d) Sampler attaches template to pre-designated sampling

location. Caution should be taken so as not to touch the area within the template.

e) Proceed to the next sampling locations and repeat procedure. When finished securing templates, have the Record Keeper take a photo of each template that includes a reference point.

f) Sampler and Record Keeper put on clean gloves. g) Record Keeper removes the corresponding sample collection

container and fills in required information on container label. h) Information consists of the date and time the sample was

taken. i) Record Keeper unscrews the container lid (always keeping the

lid in their hand). j) Sampler removes the filter paper from the container and

inspects the filter paper to ensure that it is still wet. If it has dried out, do not use it. Use one of the extra sample collection containers you brought for unexpected occurrences.

k) Keep the filter paper folded in quarters. l) Grasp the folded filter paper between the thumb and fingers.

Place the filter paper on the surface to be sampled. Press down firmly, but not excessively, with the fingers, being careful not to touch the sample surface with thumb.

m) First Wipe: Using firm pressure, horizontally wipe the surface within the template side to side in an overlapping “Z” pattern. Wipe so that the entire selected surface area is covered. End with a scooping motion. Avoid wiping the template.

n) Second Wipe: Open the wipe and fold the sampled side in. With a clean quarter section exposed, vertically wipe the surface within the template side to side in overlapping “N” pattern. Wipe so that the entire selected surface area is covered. End with a scooping motion. Avoid wiping the template.

o) Fold the filter paper so the sampled side is folded in. p) Rough surfaces should be “blotted” uniformly, rather than

wiped. q) Sampler inserts the folded filter paper into sample collection

container. r) Record Keeper secures lid and places container back into

cooler with ice (cooler is not brought into the contaminated/decontaminated area).

s) Repeat sampling procedures outlined above at each sampling location, making sure to change gloves.

t) Follow steps I-E, Chain of Custody Record through I-I, Sample Log Form.


C. ON-SITE SAMPLING PROCEDURE FOR COMPOSITE SURFACE WIPES

1. A composite sample is the collection of multiple samples taken from

different locations that are combined and analyzed as a single sample. The sample area of each of the four wipe samples that comprise the composite sample is 25 cm² (5 cm x 5 cm). Thus, the total area for each composite sample group equals 100 cm².

To collect a composite sample that accurately represents the condition of the drug lab, the sample consists of four discrete samples collected from:

• Four surface areas each measuring 25 cm². • Similar surfaces or media. • An area where contamination is expected to be relatively

evenly dispersed.

It is at the discretion of the local health staff to determine where to collect the composite samples.

2. A separate filter paper is used for each sample location. Thus, each

composite sample group will include four filter papers. Before sampling, each filter paper is stored in individual containers to prevent wetted filter papers from sticking together and tearing.

3. Follow the same sampling procedures outlined for discrete surface

wipe samples with the following exceptions: a) The same pair of gloves may be used to collect each of the

four samples that comprise the composite sample group. However, each set of composite sample groups will require use of a new pair of gloves.

b) Use the same side of the filter paper to horizontally and vertically wipe the surface:

1. Keep the filter paper folded in quarters, and horizontally wipe the selected surface. 2. Use the same side of the filter paper used to horizontally wipe to also vertically wipe the surface.

c) Upon completion of each composite sampling group, all four of the filter papers used to collect the composite sample are placed into a single sample collection container. Only one sample collection container shall be used to store the four used composite wipes.

D. FIELD QUALITY CONTROL

1. Trip Blank:

a) A trip blank is defined in the CDL Program as a quality control check to verify that methamphetamine was not introduced during sample preparation and transport. The trip blank is taken onto the sampling site where it is carried unopened throughout the


sampling process. It is not used to wipe surfaces. The trip blank sample is transported, along with the wipe samples, to the analytical laboratory for analysis.

b) Trip blank samples should be consistent with the actual site surface wipe samples which they accompany. For example, if all samples are composites, the accompanying trip blank should consist of four filter papers. In the “area sampled” part of the chain of custody form, for a trip blank, you would write “100 cm².” The sampler should treat blank samples just like regular meth wipe samples so that the lab will not be able to distinguish them from actual site environmental meth wipe samples.

III. WASTEWATER SAMPLING Objective: To collect wastewater samples from septic tanks for waste characterization using methods that minimizeVOC losses.

A. OFF-SITE SAMPLE PREPARATION

1. Conduct Off-Site Sampling Preparation outlined in “I-B”. 2. Prior to sampling, the septic tank must have been sufficiently

excavated to indicate whether the tank consists of one or two chambers.

3. Transfer sampling equipment/supplies from on-site storage container to sampling caddy.

B. ON-SITE SAMPLING PROCEDURES

1. Remove access cover from the first (or only) chamber and locate

outlet baffle. SAMPLING LOCATION IN TANKS WITH ONE CHAMBER:

a) Samples are collected from the baffle on the outlet end of the chamber.

SAMPLING LOCATION IN TANKS WITH TWO CHAMBERS: a) Samples are collected from the baffle on the outlet end of

chamber one. 2. Move any floating surface matter away from the insertion point of the

sludge judge. Do not collect any matter in the sludge judge. 3. Follow instructions for correct usage of a sludge judge. 4. Insert the sludge judge into the tank, lowering it until you hit the

bottom. 5. Trap the sample inside the sludge judge. 6. Remove the sludge judge and fill two 40ml vials. 7. Samples may be taken without preservative (procedure “a”) or with

preservative (procedure “b”) in the vial. Sampling procedure is determined by the sampler‘s confidence and ability to maintain sample integrity.


a) FIELD SAMPLE TAKEN WITHOUT A PRESERVATIVE

IN THE VIAL (1) Notify and coordinate with the analytical laboratory that

you will be submitting unpreserved samples. (2) Empty the collected sample into a stainless steel or

glass container that is large enough to hold the entire amount.

(3) Use a pipette, or stainless steel cup to fill vial to the top, leaving no headspace.

(4) Secure the lid. Check for air bubbles by slapping the vial‘s side against the palm of your hand and turning the vial upside down. If there is an air bubble larger than a pea, remove the lid and add more sample. Repeat until no air bubbles larger than a pea exist.

(5) Place sample containers in cooler with enough ice or ice packs to maintain temperature of 4° C.

(6) Samples with no preservatives must be immediately delivered or mailed to the laboratory.

b) FIELD SAMPLE TAKEN WITH A PRESERVATIVE IN THE VIAL

(1) Empty the collected sample into a stainless steel or glass container that is large enough to hold the entire amount.

(2) Use a pipette, or stainless steel cup to fill vial to the top, leaving no headspace. Take extra precaution not to cause overflow, resulting in loss of the preservative.

(3) Secure lid. Check for air bubbles by slapping the vial‘s side against the palm of your hand and turning the vial upside down. If there is an air bubble larger than a pea, remove the lid and add more sample. Repeat until no air bubbles larger than a pea exist. Take extra pre-caution not to cause overflow, resulting in loss of the preservative.

13. Place sample containers in cooler with enough ice or ice packs to maintain temperature of 4° C.

14. Follow steps I-E, “Chain of Custody Record” thru I-I, “Sample Log Form.”

15. Replace access cover.

C. FIELD QUALITY CONTROL 1. It is at the discretion of the local health staff to determine which QC

samples are taken. Often staff will waive the collection of duplicates or rinsates wastewater sampling. The reason for this is that at the initial stage of investigation, sampling is being conducted to determine if potential contamination exists. Based upon initial sample results, additional sampling, including QC samples, may be required at the discretion of the local health staff.


IV. COLLECTING SOIL SAMPLES

Objective: To collect soil samples for volatile organic compounds (VOC) analysis using EPA Method 5035A. This method was developed to minimize the loss of VOCs during the collection and handling of soil samples, and replaces the previous “jar-packing” method.

EPA Method 5035A establishes specific procedures for preparation and analysis for low and high soil VOC concentration samples, and for field and laboratory sample handling and preservation. Although the Method provides numerous options for collecting and handling soil samples for VOC analysis, Washington State Department of Health is requiring that certified CDL decontamination contractors abide by the following collection procedures:

1) Request the analytical laboratory to use the high soil VOC concentration

method * 2) Collect unpreserved soil samples and immediately submit to the

laboratory** 3) Use a zero headspace coring tool to collect the soil samples*** 4) Collect a minimum of one sample per location**** 5) Collect a dry weight sample*****

* Although the high concentration method is applicable to most of the commonly-encountered drug lab chemicals, it should be noted that for some chemicals, such as benzene that have soil cleanup levels below 200 ppb, the low concentration method will be necessary.

** It is crucial that you communicate and coordinate with your analytical

laboratory prior to collecting any soil samples to assure that the lab is prepared to receive, store, and analyze the samples.

*** Zero headspace samplers are airtight coring devises that provide for the

collection, storage and delivery of unpreserved soil samples, while minimizing VOC losses.

**** At sites where you suspect the presence of chemicals that have cleanup

levels above and below 200 ppb, two or more samples from the same sampling location will be required.

***** A dry weight sample of soil must be collected to allow for a determination

of moisture content, and the normalization of data to a dry-weight basis. Use approximately 10 grams of soil for the dry weight sample.

The specific Method 5035A soil sampling and handling procedures being required by DOH are described in detail below. In some situations, and only with the approval and oversight of the local health officer, other 5035A procedures, such as on-site sample preservation and use of non-zero headspace sample collection devices might be allowed. If site-specific situations arise that are more suited to these or other soil sampling methods, the CDL contractor will first need to discuss


these alternate methods with the local health officer and receive approval to use them. A. CONDUCT OFF-SITE SAMPLE PREPARATION

as OUTLINED IN “I-B (OFF-SITE SAMPLING PREPARATION”) B. ON-SITE SAMPLING PROCEDURES

Using a zero headspace sampler, the field sampler needs to: 1. Collect, cap, and label the sample. 2. Place the sample(s) on ice to maintain the sample(s) at a temperature

of 4 degrees Celsius, plus or minus 2 degrees (4° C ± 2°). 3. Deliver the sample to the lab immediately after collection.

Zero Headspace Sample Collection for High Level Analysis (≥ 200 µg/kg)

Each sample point requires a minimum of:

• One 5 gram zero-headspace sampling device, designed to be used only one time.

• One dry weight sampling container (4-ounce jar, 40 ml vial, or similar container).

• Soil sampling coring device, such as a T-handle. • Paper toweling.

Sampling procedure:

1. Designate one person as the sampler and the other as the record keeper.

2. Transfer the sampling equipment/supplies from the on-site storage container to the sampling caddy.

3. Take care to not overly disturb the soil in order to minimize the loss of VOCs.

4. Collect sample from a freshly exposed surface by scraping away the top inch of soil. Carefully remove organic debris, such as twigs, rocks, leaves, etc., from the sampling location before collecting the sample.

5. Use an EPA-approved zero headspace sampling device to collect 5 grams of soil. Upon approval by the LHJ, 25 grams of soil may be collected if extra sample volume is needed for special circumstances, such as the presence of peat moss or the need for additional laboratory analysis.

6. Remove the sampling device and sampling cap from the package and slide the plunger rod up and down to ensure plunger moves freely.

7. Push plunger rod down until the small o-ring rests against the tabs

8. Attach the T-handle to the sampling device by depressing the locking lever on the T-handle.

9. Align the slots on the sampling body with the locking pins on the T-handle and insert the sampling body into the T-handle.


10. Turn the sampling body in a clockwise direction to secure it 11. After the sampling body is secured in the T-handle, push the

sampling device into the freshly exposed soil until the coring body is completely full. When full, the small o-ring will be centered in the T-handle viewing hole.

12. Remove sampler from the soil. 13. Use paper toweling to wipe excess soil from the sampling

device coring body exterior. 14. Cap coring body while it is still on the T-handle. 15. Push the cap over flat area of ridge and twist to lock cap in

place. Cap must be seated to seal sampler. 16. Remove the capped sampler from the T-handle by depressing

the locking lever on the T-handle while twisting and pulling sampler from T-handle.

17. Lock the plunger by rotating extended plunger rod fully counter-clockwise until wings rest firmly against the tabs.

18. Attach completed tear-off label from the sampler bag to the cap on the sampling device coring body.

19. Place sampling device into the mailing pouch. 20. Place the mailing pouch in a zip-lock baggie 21. Place the sample on ice in a cooler at 4°C ± 2°. Dry Weight Sample: At least one dry weight sample must be collected for each location sampled. The dry weight sample is used by the lab for moisture content analysis so that it can normalize the soil VOC concentration to a dry-weight basis. 22. Collect dry weight sample by collecting soil adjacent to where

you collected the first sample. 23. Collect sample from a freshly exposed surface by scraping

away the top inch of soil with a stainless steel spoon. Carefully remove organic debris, such as twigs, rocks, leaves, etc., from the sampling location before collecting the sample.

24. Use a stainless steel spoon to fill the dry weight container with approximately 10 grams of soil. The dry weight sample container can be a 4-oz. wide mouth glass jar, a 40-ml VOA vial, or other suitable container.

25. Store sampling device with soil sample and dry weight sample container with soil sample at 4°C ± 2°.

26. Follow steps I-E, “Chain of Custody Record” through I-I, Sample Log Form.”

27. Deliver sample containers to the lab immediately after sampling. Include sufficient ice to maintain the samples at 4°C ± 2°.

Cemented soils, course, or rocky soils: Most zero head space sampling devices cannot be used for sampling these types of soils.


Consult with your local health officer to discuss other sampling options when these types of soil conditions are present. Non-cohesive, sandy soils: Zero head space sampling devices can be used for these types of soils by carefully scooping the soil into the sampling device and quickly capping it. For Low Level Analysis (< 200 µg/kg): Two samples are required. Follow same procedure as outlined for High Level Analysis except collect an additional sample.

C. FIELD QUALITY CONTROL:

Quality control (QC) samples are used to evaluate precision of the sampling process. Field quality control samples typically consist of blank, duplicate and equipment rinsate samples. It is at the discretion of the local health staff to determine whether QC samples are needed, and if so, what kind. LHJ staff will often waive the collection of duplicate or rinsate QC samples. The reason for this is that at the initial stage of CDL site investigation, sampling is being conducted to determine the presence of contamination. The results of these initial samples will dictate whether additional samples, including QC samples, will be required by local health staff.

References on Soil Sampling: 1. Collecting and Preparing Soil Samples for VOC Analysis. Implementation

Memorandum #5. Washington State Department of Ecology. June 17, 2004. 2. Soil VOC Sampling for EPA Method 5035A Analysis. Course ID: CHEM – 501.

Northwest Environmental Training Center, Seattle, Washington. 3. D6418-04 Standard Practice for Using the Disposable En Core Sampler for Sampling

and Storing Soil for Volatile Organic Analysis. American Society for Testing and Materials (ASTM).

4. D4547-98 Standard Guide for Sampling Waste and Soils for Volatile Organic Compounds. American Society for Testing and Materials (ASTM).

5. Closed System Purge-and-Trap and Extraction for Volatile Organics in Soil and Waste Samples. Draft Revision 1, July 2002. U.S. Environmental Protection Agency.

V. SAMPLING FOR CORROSIVES

OBJECTIVE: To collect samples from hard, non-porous surfaces to identify caustic areas that need to be neutralized or designated as dangerous waste.

A. ON-SITE SAMPLING PROCEDURE 1. Put on a clean pair of gloves. 2. Pour a small amount of deionized water onto indicator strip. 3. Place the indicator strip on the surface to be sampled. 4. Remove the indicator strip and compare the resultant color with the

kit‘s color key. 5. Repeat steps 1-4 as necessary.


VI. WATER SAMPLING

A. LAKES, STREAMS AND OTHER SURFACE WATER SAMPLES A common method for collecting water from ponds, lakes and streams is by dipping the sample bottle to obtain water at or near the surface. This technique is effective because many chemicals remain on the water surface. If physical conditions preclude the dip method or if subsurface samples are needed, alternate methods are available using a sampling jar attached to a telescoping pole, hand pumps, or weighted water samplers.

1. SAMPLING PROCEDURE

a). Collect at least one liter of water into a certified clean glass jar and secure with a Teflon-lined lid. Avoid collecting sediments.

b). Label jar, attach custody seal, and prepare sample for transport to the laboratory.

B. SURFACE SLICK SAMPLES

If water depth prevents dipping a bottle to collect a slick on the water surface, the preferred method is the —saturation“ pad technique. It may be appropriate to composite several pads for a single sample. Do not re-dip a pad or use both sides to collect a surface slick. Collected material can be washed away if the pad is re-dipped.

1. SAMPLING PROCEDURE

a. Fold an 11 cm filter paper (Whatman 40 ashless or equivalent) or gauze pad into a 2.5 cm square.

b. Grasp the pad firmly with stainless steel forceps and saturate the pad with the slick. Roll the pad into a cylinder and place into a glass jar and secure with a Teflon-lined lid.

c. Label jar, attach custody seal, and prepare sample for transport to the laboratory.

C. WELL WATER SAMPLES

Purging the Well – “Purging the well“ means removing the volume of water standing in the well casing and/or in the water distribution system and replacing that water with new water from the aquifer. The purpose is to insure that a representative sample of the aquifer is collected. 1. SAMPLING PROCEDURE

a. If there is no tap at the well head, use the closest tap to the well head.

b. Purging is not necessary on wells which are pumped continuously, but measurements of temperature, conductivity (the ability to conduct an electric current) and pH should still be recorded. If a well is pumped dry during the purging process, it may be considered adequately purged and the sample can be collected as soon as the well casing is recharged.

c. Flow may be diverted with a hose during the purging process, but the hose must be removed before samples are collected.


C. WELL WATER SAMPLES (continued) One of the following methods should be used:

Method One: Open the tap all the way and allow water to flow into a catch bucket. Water should flow for approximately five minutes before readings are taken for conductivity, temperature, and pH. After five minutes and while water continues to flow, conductivity, temperature and pH should be measured at approximate one minute intervals until three consecutive readings indicate that parameters have stabilized. Readings may be considered stable when temperature measurements vary by no more than + 0.50 C, conductivity readings vary by no more than + 1% and pH readings vary by no more than + 0.1 pH unit. It may be assumed that the source is adequately purged when stable readings for two parameters are obtained. After readings have stabilized, remove the hose and begin sampling.

Method Two: Three to five well casing water volumes (storage volumes) should be purged from the well.

The storage volume is calculated as follows:

1). Volume (V) = 3.14 x R2 x D x 7.48 gal/ft

3

V = Borehole volume (gallons) R = Radius of the well bore (feet) D = Depth of well (feet)

2). Flow should be measured using a five-gallon bucket and a stopwatch. Record readings in the field notebook.

3). Calculate the amount of time (in minutes) that the well should be purged in order to remove the required 3-5 times the well volume: Time = 3 (or 5) x Volume of borehole (in gal) required flow rate (in gal/min) in minutes

4). After the required minimum volume has been purged and while water continues to flow, conductivity, temperature and pH should be measured at approximately one minute intervals until three consecutive readings indicate that parameters have stabilized. These measurements should be recorded in the field notebook. Samples should be collected after the required well volume has been purged and readings for conductivity, temperature, and pH have stabilized.

2. FIELD MEASUREMENTS

Specific conductivity, pH and temperature should be measured on-site and during purging of the well. Well water should be


C. WELL WATER SAMPLES (continued) pumped continuously into a bucket or other container until three consecutive readings taken at one minute intervals indicate the three parameters have stabilized.

a) Conductivity - The conductivity of a water sample gives

an indication of the concentration of dissolved solids in the water. Conductivity should be measured with a temperature-compensated instrument, reading directly in micromhos/cm at 25oC. The cell should be checked before initial use and unless otherwise stated by the manufacture. The instrument should be calibrated daily during regular use against a 0.00702 N potassium chloride (KCl) solution with a specific conductivity of 1,000 micromhos/cm at 25oC. Routine checks are made by using a standard solution within the anticipated conductivity range of the sample at ambient temperature.

b). Temperature - Temperature should be recorded by an

electronic reading thermometer or mercury thermometer accurate to + 0.5o C.

c). Hydrogen Ion Concentration (pH) - The pH of a solution

is a measure of the effective hydrogen ion concentration. It should be measured with an instrument having an accuracy of 0.1 units. Since pH is temperature sensitive, it is important that pH calibration standards be within +1oC of the sample solution for precise determinations.

3. SAMPLE COLLECTION

a. Samples should be collected as close to the well as possible, from a tap located before the water has passed through any pressure or water storage tanks or treatment systems. If it is not possible to collect a sample from the water system before the well water storage tank, then the volume of water in the storage tank must be taken into account when purging the system.

b. There should be sufficient space to place the bottle under the tap without grazing the neck interior against the faucet.

c. Leaking taps which allow water to flow out from around the stem of the valve handle and down the outside of the faucet, or taps in which water tends to run up on the outside of the lip, should be avoided as sampling locations.

d. Aerator, strainer, and hose attachments on the tap should be removed before sampling. If a steady stream of water cannot be obtained from the tap after removing such devices, a more suitable tap should be sought.


C. WELL WATER SAMPLES (continued) e. Water flow should be steady to avoid dislodging material

lining the inside of the pipe. A smooth-flowing stream at moderate pressure without splashing should be obtained. Water flow should not be adjusted immediately prior to or during actual sample collection.

f. Excessive flow and the resulting turbulence can affect metals, volatile organics, and many other chemicals. Samples should be disturbed as little as possible (e.g., turbulence, agitation, and exposure of water sample and containers to the atmosphere).

g. During sample collection, the bottle cap should not be placed on the ground or in a pocket. The bottle should be held in one hand and the cap in the other, keeping the bottle cap right side up (threads down) using care not to touch the inside of the cap. Be careful to avoid losing the Teflon liner in certain

bottle caps. Avoid contaminating the sample bottle with fingers or permitting the faucet to touch the inside of the bottle. When filling any container, care should be taken that splashing drops of water from the ground or sink do not enter either the bottle or cap. A clean polyethylene sheet placed on the ground may be helpful in maintaining a clean work area.

h. Samples should be labeled and held on ice, if required, immediately after collection.

i. Samples should be collected in the following order: #1) Volatile Organic Compounds (VOC) #2) Other Organic Compounds, Metals and Inorganics

4. Volatile Organic Compounds (VOC)

a. Samples to be analyzed for purgeable organic compounds should be taken in 40 ml vials and secured with screw caps containing a Teflon septum.

b. Two vials should be filled for each sample.

c. The investigator should determine if the water to be sampled contains chlorine. If the water contains no chlorine, two 40 ml vials, each containing 2 drops of 1:1 HCl, should be filled with the sample and labeled. If the sample contains no chlorine and only if the sample will be analyzed within 24 hours, preservation with HCl is not necessary.

d. Samples should be collected before chlorination or other pre-treatment if at all possible. If this is not possible and the sample contains chlorine, the following procedure for sample collection and preservation should be followed:

e. Fill a 40 ml vial, containing 10 mg sodium thiosulfate, to the shoulder (where the vial necks down to the top) with sample,


C. WELL WATER SAMPLES (continued) add 2 drops of 1:1 HCl, then fill completely with sample. Label the vial.

NOTE: Sodium thiosulfate and acid preservatives should be

added in this order and in two separate steps because HCl reacts with sodium thiosulfate.

f. Vials should be completely filled, with no air bubbles. Extreme caution should be exercised when filling a vial, to avoid any turbulence which could also produce volatilization. The sample should be carefully poured down the side of the vial to minimize turbulence. As a rule, it is best to gently pour the last few drops into the vial so that surface tension holds the water in a “convex meniscus”. The cap is then applied and some overflow may be lost, but air space in the bottle is eliminated. After capping, turn the bottle over and tap it to check for bubbles; if any are present, discard the sample and sample bottle and repeat the procedure with a new bottle.

5. Other Organic Compounds, Metals, and Inorganics

a. All containers and tubing, used for collection of samples for other organic compounds, metals and inorganic analysis, should be prepared as provided by standard cleaning procedures.

b. When possible, the sample should be collected directly into the appropriate sample container. If this cannot be physically accomplished, an intermediate collection device may be used, such as a smaller sampling bottle, which has been cleaned according to standard procedures.

REFERENCES

1. American Society for Testing and Materials D4840 œ99 Chain-of-Custody Procedures

2. American Society for Testing and Materials E 1728-99 Field Collection of Settled Dust Samples Using Wipe Sampling Methods for Lead Determination by Atomic Spectrometry Techniques

3. American Society for Testing and Materials D 4547 Sampling Waste and Soils for Volatile Organic Compounds

4. United States Department of Housing and Urban Development Lead Wipe Sampling for Contaminated Dust

5. United States Environmental Protection Agency EPA SW 846-5035 EPA 600482029 Handbook for Sampling and Sample Preservation of Water and Wastewater

Washington State Department of Health’s Clandestine Page A-1 Drug Lab Program Decontamination Standards

APPENDIX A Rationale for the Establishment of the Washington State Department of Health’s Clandestine Drug Lab Program Decontamination Standards July 2005 Washington State passed legislation in 1990 mandating the cleanup of properties contaminated by illegal clandestine drug lab (CDL) activity in order to protect the health of future occupants of the properties1 The legislation authorized the Washington State Department of Health (DOH) to develop numeric decontamination standards and certify cleanup contractors to evaluate and clean up illegal drug labs. The goal of the decontamination standards is to provide protection for all people, particularly for infants and children, who are thought to be the most susceptible to the toxic effects of residual chemicals. This susceptibility is a result of numerous factors, including the young child’s developing physiology, higher intake of food, air, and fluids in proportion to their body weight compared to adults, and their unique behavior patterns. The decontamination standards must be attained before local health jurisdictions (LHJs) can clear a residence for reoccupancy.

The standards were developed to address chemicals associated with the manufacture of methamphetamine, since these types of labs represent the majority of illegal drug labs in Washington State. As new illegal drug manufacturing methods and processes are developed, and different chemicals and byproducts are produced, additional standards may need to be incorporated in the regulation. Although a large variety of chemicals may be found at illegal methamphetamine manufacturing labs, DOH selected four of primary concern commonly associated with these types of labs; methamphetamine, total volatile organic compounds (VOCs), lead, and mercury. The decontamination standards are listed in section 541 of Chapter 246-205 WAC, and are as follows:

Chemical Type of sample Decontamination standard Methamphetamine (1) Surface area wipe ≤ 0.1 µg/100cm2

Total Volatile Organic Compounds (VOCs) (2)

Air 1 ppm

Lead (total) (3) Surface area wipe ≤ 20 µg/ft2 Mercury (4) Air ≤ 50 ng/m3

(1) Units are in micrograms of methamphetamine per one hundred square centimeters of surface area. (2) Units are in parts per million. (3) Units are in micrograms of lead per square foot of surface area. (4) Units are in nanograms of mercury per cubic meter of air.

(one thousand nanograms equals one microgram).


Methamphetamine Standard DOH reviewed the scientific literature on the health effects of methamphetamine and other amphetamine-related drugs. These studies focused primarily on prenatal exposure during pregnancy in humans and on high dose studies in animals. Studies on the health effects associated with chronic exposures to low concentrations of methamphetamine are not available. Human and Animal studies The effect of methamphetamine on the development of the nervous system is known from studies of fetuses exposed in the womb of female methamphetamine users. No studies have evaluated the health effects of children directly exposed to methamphetamine in illegal drug labs. The studies have shown significantly lower intelligence testing scores compared to infants not exposed in the womb, and that those exposed may be at risk later in life for subtle neurological abnormalities.2 Numerous physical malformations resulting from prenatal exposure to amphetamine and methamphetamine have been reported including cleft lip, cardiac defects, low birth weight, reduced head circumference, biliary atresia, cerebral hemorrhage, low body fat, systolic murmur, and undescended testes.3 Numerous animal studies have been conducted to evaluate the health effects of methamphetamine exposure. Studies conducted on rats and monkeys have demonstrated the adverse effects of methamphetamine on the central nervous system, selective reductions in brain serotonin and dopamine concentrations, and neurological damage. 4 In a 1998 study, rats exposed to methamphetamine were observed to have increased occurrences of retinal hemorrhages compared to control groups.5 In another 1998 study conducted on baboons, methamphetamine produced long-term decreases on brain dopamine axonal markers at all doses tested.6 In a 1994 rat study, methamphetamine-treated groups exhibited reduced locomotor activity compared to untreated groups.7 A 2003 rat study supported the position that neonatally methamphetamine-exposed animals may exhibit hypoactivity.8 In other studies, reduced body weights were observed in rats exposed to methamphetamine. DOH’s Approach A quantitative exposure/risk assessment was not conducted during development of the methamphetamine standard, since studies about the potential long-term health risks associated with chronic, low-level exposure to methamphetamine are not available, controlled human exposure studies are unlikely for ethical reasons, and available toxicity data are limited. Washington State adopted a preventative approach that recognized the potential of the magnitude of childhood exposures and associated health risks because of the number of children found living in residential CDLs. Because of the extent of the CDL problem in Washington State, DOH did not want to wait for the derivation of methamphetamine-specific toxicity factors and the completion of a quantitative risk assessment before establishing a decontamination standard for methamphetamine. DOH chose to adopt a feasibility-based approach when establishing the current methamphetamine standard. This approach was based on the following primary considerations:


1. Analytical limitations and; 2. A cleanup level to which methamphetamine could reasonably be achieved.

Currently, other states, private researchers, and the National Alliance for Model State Drug Laws are working towards the assessment of appropriate indicator chemicals and the development of health-based decontamination standards that state and local drug lab programs can choose to adopt when assessing and remediating illegal drug labs. In addition, federal legislation is being introduced to address site assessment and remediation issues, and to identify new methamphetamine detection technologies, research needs, and other data gaps. DOH will continue to use its current methamphetamine decontamination standard until additional research demonstrates the appropriateness of a different standard. In February 2005, the Colorado Department of Public Health (CDPH) prepared a paper that attempted to correlate existing states’ detection-based cleanup standards for methamphetamine to known health-effect-based concentrations.9 In doing so, CDPH estimated residential methamphetamine exposures using standard exposure assumptions. Using these standard exposure assumptions, the estimated dose for an infant exposed to 0.1ug/100 cm2 methamphetamine (the Washington State decontamination standard) was 50 times lower than the most protective reference dose derived by CDPH. The reference dose was based on reproductive toxicity. What this indicates is that the current Washington State methamphetamine decontamination standard appears to be well below levels that would be expected to cause adverse noncancer health effects, such as reproductive toxicity, for persons chronically exposed to methamphetamine at the 0.1 ug/100cm2 decontamination standard. Total Volatile Organic Compounds (VOC) Standard Volatile Organic Compounds (VOCs) were recognized as being common to all CDL sites. VOCs include many different chemical compounds, a number of which are used in the manufacture of illegal drugs including toluene, acetone, methanol, petroleum distillates, and ethers, among others. DOH believed it was most practical and cost-effective to test for total VOCs, rather than require testing for dozens of individual VOCs in air. Using the portable photoionization detector (PID), total VOCs can routinely be detected at the 1 part per million (ppm) level. When establishing the VOC standard, DOH also recognized that by the time the remediated residences are reoccupied, levels of VOCs are expected to be lower as a result of the removal of the primary sources of the VOCs, such as the bulk chemicals and porous household materials. Additionally, volatilization of residual VOCs to significantly lower levels will likely have occurred. DOH also recognized the fact that studies have documented the presence of “background” levels of VOCs in ambient and indoor air.10 Sources of these background VOCs include industrial and automobile emissions, consumer products, and building materials, among others. For this reason, it was not realistic for DOH to require VOC levels to be zero or below reasonable background levels.


Lead (Pb) Standard

DOH recommends testing for lead only at residences where it is evident that the amalgam (P2P) method or other methods involving lead were used. Currently, methods involving lead are rarely seen at drug lab sites in Washington State. The health effects from chronic exposure to lead, and its particular health implications for fetuses, infants, and toddlers are well documented. Young children and the developing fetus are more vulnerable to lead poisoning than adults. Lead can affect almost every organ and system in the body, the most sensitive being the central nervous system. Lead also damages kidneys and the reproductive system.11

DOH considered existing health and toxicity information when establishing the decontamination standard for lead. DOH also considered the presence of background levels of lead often found in older homes, since lead-based paint is frequently present in such homes where many illegal drug labs are found. The current 20 micrograms per square foot (20 µg/ft2) lead wipe standard is one half of the U.S. Department of Housing and Urban Development’s (HUD) current floor wipe clearance standard and one half of the U.S. Environmental Protection Agency’s (EPA) lead hazard standard. DOH also considered the growing body of scientific data that indicates the blood lead threshold for adverse health effects, including nervous system effects, is lower than the CDC’s current 10 micrograms of lead per deciliter of blood lead level of concern. Given this data, DOH believed it was prudent to establish a lower lead wipe standard than the current HUD and EPA standards. Mercury (Hg) Standard DOH recommends testing for mercury only at residences where it is evident that the amalgam (P2P) method, or other methods involving mercury were used. Currently, methods involving mercury are rarely seen at drug lab sites in Washington state. Exposure to mercury can harm the brain, heart, kidneys, lungs, and immune system of people of all ages. Short-term exposure to high levels of metallic mercury vapors may cause lung damage, increases in blood pressure or heart rate, skin rashes, and eye irritation. Inhalation of mercury vapor is particularly harmful. Fetuses and young children are more sensitive to mercury’s health effects than adults. Mercury's effects upon the fetus include brain damage, mental retardation, incoordination, blindness, seizures, and inability to speak. A nursing infant can also be exposed to mercury from breast milk. High levels of mercury in the bloodstream of the fetus and young child may harm the developing nervous system.12

The mercury decontamination standard is more protective than current Washington State Department of Ecology and federal health/risk-based screening levels for mercury. Because of the severity of health effects associated with mercury exposure, DOH chose to use the lowest measurable amount using standard sampling and analytical methods as the basis of the standard. DOH also established a lower mercury standard than existing state and federal health-based screening levels to account for cumulative exposures from other sources of mercury, such as from diet, air, dental amalgams, and some commercial paints. For example, ambient background concentrations of mercury in air have been documented, and are reported to average approximately 10-20 ng/m3, with higher


concentrations in industrialized areas.13 To account for these background exposures or “body burdens”, DOH set the mercury decontamination standard below existing health-based screening levels.

References 1 Chapter 246-205 WAC – Decontamination of Illegal Drug Manufacturing or Storage Sites, June 18, 2003 Update. 2 Struthers MD and Hansen RL. Visual recognition memory in drug-exposed infants. J Dev Behav Pediatr. 1992;13(2): 108-111. 3 Plessinger MA. Prenatal exposure to amphetamines. Obs Gyn Clin North Am. 1998;25(1):119-138. 4 Ricaurte G, Bryan G, Strauss L, Seiden L, and Schuster C. Hallucinogenic amphetamine selectively destroys brain serotonin nerve terminals. Science. 1988;94:448-457. 5 J. Gomes-Da-Silva, M. C. Silva and M. A. Tavares. Developmental Exposure to Methamphetamine: A Neonatal Model in the Rat. Annals of the New York Academy of Sciences 844:310-313 (1998). 6 Villemagne, V, Yuan J, Wong DF, Dannals RF, Hatzidimitriou G, Mathews VB, Ravert HT, Musachio J, McCann UD, and Ricaurte GA. Brain Dopamine Neurotoxicity in Baboons Treated with Doses of Methamphetamine Comparable to those Recreationally Abused by Humans: Evidence from [

11C]WIN-35,428 Positron Emission Tomography

Studies and Direct In Vitro Determinations. The Journal of Neuroscience, 1998. 18(1): 419-427. 7 Vorhees CV, Ahrens KG, Acuff-Smith KD, Schilling MA, Fisher JE. 1994. Methamphetamine Exposure During Early Postnatal Development in Rats: II. Hypoactivity and Altered Responses to Pharmacological Challenge. Psychopharmacology. 114: 402-408. 8 Williams, MT., Blankenmeyer TL, Schaefer TL, Brown CA, Budelsky GA, and Vorhees CV. 2003. Long-term Effects of Neonatal Methamphetamine Exposure in Rats on Spatial Learning in the Barnes Maze and on Cliff Avoidance, Corticosterone Release, and Neurotoxicity in Adulthood. Developmental Brain Research 147: 163-175. 9 Support for Selection of a Cleanup Level for Methamphetamine at Clandestine Drug Labs, Colorado Department of Public Health and Environment, Feb. 2005. 10 JP Kurtz (Environmental & Mining Systems International, Inc., Longmont, CO, USA) and DJ Folkes (EnviroGroup Ltd., Englewood, CO, USA). Background Concentrations of Selected Chlorinated Hydrocarbons in Residential Indoor Air. Proceedings: Indoor Air 2002. 11 U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry. Toxicological Profile for Lead. July 1999.


12 U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry. Toxicological Profile for Mercury, March 1999. 13 U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry. Toxicological Profile for Mercury, March 1999.

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AB 1078HSC 25400.10-45

AB 1078HSC 25400.10-45

Methamphetamine Contaminated Property Cleanup Act of 2005

Methamphetamine Contaminated Property Cleanup Act of 2005

Article 1, Findings & DefinitonsArticle 1, Findings & Definitons• Designated Agency: designated by LHO

– CUPA– Fire or Environmental Health– Local Agency enforcing Housing Law

• PSA Workplan• PSA Report• Property Owner (excludes mobile homes)

– Hopefully to be corrected by AB 2587

• Designated Agency: designated by LHO– CUPA– Fire or Environmental Health– Local Agency enforcing Housing Law

• PSA Workplan• PSA Report• Property Owner (excludes mobile homes)

– Hopefully to be corrected by AB 2587

Article 2, Establishment of Remediation and Re-occupancy Standards

Article 2, Establishment of Remediation and Re-occupancy Standards

• 25400.16: Standards for safe human occupancy• 20 μg/ft2 lead• 50 ng/m3 Hg• 0.1 μg/100 cm2 meth

– These levels change when OEHHA adopts a health-based target remediation standard for meth

• 25400.16: Standards for safe human occupancy• 20 μg/ft2 lead• 50 ng/m3 Hg• 0.1 μg/100 cm2 meth

– These levels change when OEHHA adopts a health-based target remediation standard for meth

Other State StandardsOther State Standards

Article 3: LHO ResponsibilitiesArticle 3: LHO Responsibilities• 25400.17 :

– City/County will comply with the uniform regulations of this chapter.

– LHO can delegate– If meth lab activity has taken place, LHO

shall assume that meth manufacture has led to some degree of chemical contamination and take action pursuant to this chapter

• 25400.17 :– City/County will comply with the uniform

regulations of this chapter.– LHO can delegate– If meth lab activity has taken place, LHO

shall assume that meth manufacture has led to some degree of chemical contamination and take action pursuant to this chapter

25400.1825400.18• W/in 48 hrs of notification by law enforcement,

LHO post notice• “Warning”• statement meth lab seized there• date of seizure• address/location• name and contact # of agency posting property• statement hazardous chemicals/waste may be present• unlawful to enter until advised it is safe to do so• statement that anyone destroying the notice is subject

to civil penalty up to $5K• statement that anyone who violates the notice is subject

to civil penalty up to $5K

• W/in 48 hrs of notification by law enforcement, LHO post notice• “Warning”• statement meth lab seized there• date of seizure• address/location• name and contact # of agency posting property• statement hazardous chemicals/waste may be present• unlawful to enter until advised it is safe to do so• statement that anyone destroying the notice is subject

to civil penalty up to $5K• statement that anyone who violates the notice is subject

to civil penalty up to $5K

25400.19 25400.19 • W/in 5 working days of notice by law

enforcement, LHO shall inspect the property, including evidence of chemical use, staining, release, spillage. LHO may request copies of law enforcement reports or HW manifests to evaluate the following:

• W/in 5 working days of notice by law enforcement, LHO shall inspect the property, including evidence of chemical use, staining, release, spillage. LHO may request copies of law enforcement reports or HW manifests to evaluate the following:

– length of time property used for manufacture or storage

– extent of the property actually used– chemical process involved– chemicals that were removed– location of the manufacture/storage relative

to habitable areas

– length of time property used for manufacture or storage

– extent of the property actually used– chemical process involved– chemicals that were removed– location of the manufacture/storage relative

to habitable areas

25400.20 25400.20 • Upon completion of inspection, LHO

determines if contamination present. If so, see 25400.22. If not contaminated, LHO has 3 days to remove posted notices and prepare documentation that states:• findings and conclusions• name of property owner• parcel id

– within 10 d of non-contamination determination, LHO shall send a copy to the property owner and the local agency responsible for housing law enforcement.

• Upon completion of inspection, LHO determines if contamination present. If so, see 25400.22. If not contaminated, LHO has 3 days to remove posted notices and prepare documentation that states:• findings and conclusions• name of property owner• parcel id

– within 10 d of non-contamination determination, LHO shall send a copy to the property owner and the local agency responsible for housing law enforcement.

25400.2225400.22• (a) W/in 10 working days of determining

contamination, LHO shall:(1) if real property, record with county recorder a lien on

the property:o the name of the agencyo the date on which the property is determined to be

contaminatedo the legal description and assessor’s parcel #o record owner of propertyo amount of lien, either $200 or costs incurred by LHO,

including inspection and recorders fee

(2) Issue an order to occupants of the property, outstanding persons and country recorders office that occupancy is prohibited

• (a) W/in 10 working days of determining contamination, LHO shall:(1) if real property, record with county recorder a lien on

the property:o the name of the agencyo the date on which the property is determined to be

contaminatedo the legal description and assessor’s parcel #o record owner of propertyo amount of lien, either $200 or costs incurred by LHO,

including inspection and recorders fee

(2) Issue an order to occupants of the property, outstanding persons and country recorders office that occupancy is prohibited

(c) Force of a judgment lien. Cannot be removed untilo Property owner satisfies the lien and LHO issues

release in 25400.27o Lien otherwise released under applicable law

(d) Lien issued by certified mail or in person to occupants and owner

(e) If whereabouts of persons unknown,….(f) LHO shall mail copy to anyone with interest in

property

(c) Force of a judgment lien. Cannot be removed untilo Property owner satisfies the lien and LHO issues

release in 25400.27o Lien otherwise released under applicable law

(d) Lien issued by certified mail or in person to occupants and owner

(e) If whereabouts of persons unknown,….(f) LHO shall mail copy to anyone with interest in

property

• Order shall include:– Description of property– Parcel #– Vehicle id# if applicable– Description of LHOs course of action– Specification of penalties for non-compliance– Prohibition on use of portions of property

contaminated– Description of measures property owner will have to

take to decontaminate the property– Indication of the potential health hazards involved– Statement that the property owner who fails to

provide disclosure is subject to $5K penalties

• Order shall include:– Description of property– Parcel #– Vehicle id# if applicable– Description of LHOs course of action– Specification of penalties for non-compliance– Prohibition on use of portions of property

contaminated– Description of measures property owner will have to

take to decontaminate the property– Indication of the potential health hazards involved– Statement that the property owner who fails to

provide disclosure is subject to $5K penalties

(h) LHO provide copy to agency responsible for house law enforcement

(i) LHO to post order in conspicuous place on property within 1 working day

(h) LHO provide copy to agency responsible for house law enforcement

(i) LHO to post order in conspicuous place on property within 1 working day

Article 4: Site Assessment and Remediation

Article 4: Site Assessment and Remediation

• 25400.25 – Property owner/occupant shall immediately

vacate property– Within 30 days, PO shall demonstrate that a

drug lab remediation firms has been retained

• 25400.25 – Property owner/occupant shall immediately

vacate property– Within 30 days, PO shall demonstrate that a

drug lab remediation firms has been retained

• 25400.26 – PO shall use authorized contractor, retain

documentation for 3 years after place is considered habitable.

– PO/Contractor shall submit PSA Work plan within 30 days after being retained

– Within 10 working days of PSA Work plan submitted, LHO shall review to determine compliance with 25400.35. If deficiencies, LHO shall notify PO within 15 days of date plan submitted. If approved, LHO shall notify PO within 15 days.

– Once PSA done, PO/Contractor shall prepare PSA Report (25400.37) and submit.

– If PSA report indicates no contamination requiring remediation, LHO acts (25400.27)

– Once PSA Work plan approved by LHO, must be completed w/in 90 days.

• 25400.26 – PO shall use authorized contractor, retain

documentation for 3 years after place is considered habitable.

– PO/Contractor shall submit PSA Work plan within 30 days after being retained

– Within 10 working days of PSA Work plan submitted, LHO shall review to determine compliance with 25400.35. If deficiencies, LHO shall notify PO within 15 days of date plan submitted. If approved, LHO shall notify PO within 15 days.

– Once PSA done, PO/Contractor shall prepare PSA Report (25400.37) and submit.

– If PSA report indicates no contamination requiring remediation, LHO acts (25400.27)

– Once PSA Work plan approved by LHO, must be completed w/in 90 days.

• 25400.27 – If LHO determines property has been

remediated, LHO shall issue “no further action” determination. W/in 10 working days of the determination or receiving payment for lien (whichever is later), LHO shall:

• Release the lien; the release shall specify:o Name of agency who filed lieno Recording date of releaseo Legal description and APNo Record owner of propertyo Recording instrument, or book & page of the lien being

released• Send a copy of the release stating the property is

remediated, does not violate human occupancy standards to the PO, Local Housing Agency and recipients in 25400.22

• 25400.27 – If LHO determines property has been

remediated, LHO shall issue “no further action” determination. W/in 10 working days of the determination or receiving payment for lien (whichever is later), LHO shall:

• Release the lien; the release shall specify:o Name of agency who filed lieno Recording date of releaseo Legal description and APNo Record owner of propertyo Recording instrument, or book & page of the lien being

released• Send a copy of the release stating the property is

remediated, does not violate human occupancy standards to the PO, Local Housing Agency and recipients in 25400.22

• 25400.28 – Until PO receives no further action notice

from LHO, PO shall:– Notify prospective buyers of pending order

and provide copy. Prospective buyer shall acknowledge receipt of order in writing.

– Provide written notice to tenants who have applied to rent. They shall provide written receipt before signing of lease. Notice shall be attached to lease.

• 25400.28 – Until PO receives no further action notice

from LHO, PO shall:– Notify prospective buyers of pending order

and provide copy. Prospective buyer shall acknowledge receipt of order in writing.

– Provide written notice to tenants who have applied to rent. They shall provide written receipt before signing of lease. Notice shall be attached to lease.

Article 5. Remediation of Contaminated Property by a City or County

Article 5. Remediation of Contaminated Property by a City or County

• 25400.30 – If PO doesn’t comply, local govt can take action to

either remediate or get court order to force PO to cleanup. If LHO can’t find PO within 10 days, govtmay remediate. If govt remediates, PO is liable for all costs, including, but not limited to:

• Posting and securing the property• Notification of affected people• Actual expenses related to recovery of cost, lab fees,

cleanup services, removal costs, admin and filing fees

– If PO doesn’t pay up, govt may place nuisance abatement lien on property

• 25400.30 – If PO doesn’t comply, local govt can take action to

either remediate or get court order to force PO to cleanup. If LHO can’t find PO within 10 days, govtmay remediate. If govt remediates, PO is liable for all costs, including, but not limited to:

• Posting and securing the property• Notification of affected people• Actual expenses related to recovery of cost, lab fees,

cleanup services, removal costs, admin and filing fees

– If PO doesn’t pay up, govt may place nuisance abatement lien on property

Article 6: Requirements for Property Assessment and Cleanup

Article 6: Requirements for Property Assessment and Cleanup

• 25400.35 – LHO shall establish a written plan for

conducting the remediation, including procedures for PSA Work plan preparation, conducting the PSA, preparation of the PSA Report

• 25400.35 – LHO shall establish a written plan for

conducting the remediation, including procedures for PSA Work plan preparation, conducting the PSA, preparation of the PSA Report

• 25400.36 – PSA Work plan shall include:

• Physical description of the property• Summary of the info from law enforcement, LHO including

discussion of the relevance to the contamination including areas suspect of contamination

o Duration o flab operation and # batches cookedo Hazardous chemicals manufacturedo Recipes and methods usedo Chemicals/equipment found by locationo Location of contaminated cooking/storage areaso Visual assessment of severity of contamination inside and outside

of the structureo Assessment of contamination in adjacent rooms, structureso Disposal methods observed at or near the site, including

dumping, burning, burial, venting or drain disposalo Comparison of the chemical on the manifest with known methods

of mfgo Determination whether method indicated the use of mercury or

lead, including lead acetate, mercuric chloride, mercuric nitrate

• 25400.36 – PSA Work plan shall include:

• Physical description of the property• Summary of the info from law enforcement, LHO including

discussion of the relevance to the contamination including areas suspect of contamination

o Duration o flab operation and # batches cookedo Hazardous chemicals manufacturedo Recipes and methods usedo Chemicals/equipment found by locationo Location of contaminated cooking/storage areaso Visual assessment of severity of contamination inside and outside

of the structureo Assessment of contamination in adjacent rooms, structureso Disposal methods observed at or near the site, including

dumping, burning, burial, venting or drain disposalo Comparison of the chemical on the manifest with known methods

of mfgo Determination whether method indicated the use of mercury or

lead, including lead acetate, mercuric chloride, mercuric nitrate

– Description of the areas to be sampled and basis for the selection. Indicate decision process used to determine where NOT to sample. PSA WP include primary and secondary areas of concern

• Primary areas include:o Obvious stainingo Processing/cooking area; may include floors, walls,

ceilings, glassware, working surfaces, furniture, carpeting, draperies, plumbing fixtures and drains, HVAC vents

o Any disposal area including sinks, toilets, bathtubs, plumbing traps and floor drains, vents, vent fans, chimney flues. Outdoor areas contaminated by burning or dumping on soil, surface water, groundwater, sewer, septic and cesspools.

o Chemical storage areas contaminated by leaks, spills

– Description of the areas to be sampled and basis for the selection. Indicate decision process used to determine where NOT to sample. PSA WP include primary and secondary areas of concern

• Primary areas include:o Obvious stainingo Processing/cooking area; may include floors, walls,

ceilings, glassware, working surfaces, furniture, carpeting, draperies, plumbing fixtures and drains, HVAC vents

o Any disposal area including sinks, toilets, bathtubs, plumbing traps and floor drains, vents, vent fans, chimney flues. Outdoor areas contaminated by burning or dumping on soil, surface water, groundwater, sewer, septic and cesspools.

o Chemical storage areas contaminated by leaks, spills

• Secondary areas include:o Location where contamination may have migrated, e.g.

hallways, high traffic areaso Common areas in multiple dwellings and adjacent apts

or rooms including floors, walls, ceilings, furniture, carpet, lights, blinds, draperies

o Common ventilation or plumbing systems in hotels and multiple dwellings

– Sampling protocols, analytical methods and labs used with relevant accreditations

– Description of areas and items that will be remediated in lieu of sampling, if any

• Secondary areas include:o Location where contamination may have migrated, e.g.

hallways, high traffic areaso Common areas in multiple dwellings and adjacent apts

or rooms including floors, walls, ceilings, furniture, carpet, lights, blinds, draperies

o Common ventilation or plumbing systems in hotels and multiple dwellings

– Sampling protocols, analytical methods and labs used with relevant accreditations

– Description of areas and items that will be remediated in lieu of sampling, if any

• 25400.37 – After PSA completed, a PSA Report shall be

prepared and submitted to LHO. PSA Report shall include:

• Location of the site, street add and mailing address of property, owner of record and mailing address, legal description and clear directions for locating the property

• Site map w/diagram of contaminated property, including

o Floor plan of affected buildingso Local drinking water wells and nearby streams or

surface water potentially affectedo Location of damage and contaminationo Location of sampling points used in PSA, keyed to

sampling results and remediation recommendations

• 25400.37 – After PSA completed, a PSA Report shall be

prepared and submitted to LHO. PSA Report shall include:

• Location of the site, street add and mailing address of property, owner of record and mailing address, legal description and clear directions for locating the property

• Site map w/diagram of contaminated property, including

o Floor plan of affected buildingso Local drinking water wells and nearby streams or

surface water potentially affectedo Location of damage and contaminationo Location of sampling points used in PSA, keyed to

sampling results and remediation recommendations

– Description of the sampling and analytical protocols used

– Description of sampling results– Info regarding the background samples and

results obtained– Specific recommendations, including

methods of remedial actions to meet human occupancy std

– Plan for post remediation site assessment, including specific sampling requirements and methodologies an locations at which samples are to be obtained

– Description of the sampling and analytical protocols used

– Description of sampling results– Info regarding the background samples and

results obtained– Specific recommendations, including

methods of remedial actions to meet human occupancy std

– Plan for post remediation site assessment, including specific sampling requirements and methodologies an locations at which samples are to be obtained

• 25400.38 – PSA WP and PSA Report shall be signed,

notarized by contactor responsible for completion of the PSA and by a CIH for sufficiency and completeness

• 25400.40 – A person shall not perform PSA or

remediation work until person has completed:

• 5192 40-hr training• annual refresher• additional requirements by LHO• training shall be certified by paragraph 6 of 5192e

– instructor certifies they completed the training

• 25400.38 – PSA WP and PSA Report shall be signed,

notarized by contactor responsible for completion of the PSA and by a CIH for sufficiency and completeness

• 25400.40 – A person shall not perform PSA or

remediation work until person has completed:

• 5192 40-hr training• annual refresher• additional requirements by LHO• training shall be certified by paragraph 6 of 5192e

– instructor certifies they completed the training

Other States Training RequirementsOther States Training Requirements• Arizona

– In addition to 40 hr, and 8 hr training• AHERA and Lead certificate (Supervisor)• Attend two 8 hr courses on clan lab cleanup within 1st year• Attend 2 hr Refresher course on clan lab cleanup every year

thereafter• Oregon

– Sampling personnel• CIH or BS in Science working under OSHA, EPA or Industrial

Hygiene firm– Contractors and personnel

• State mandated training (pass test w/70% or greater)• Annual refresher course

• Washington– 2 day course for workers, additional day course for supervisors– Annual refresher

• Arizona– In addition to 40 hr, and 8 hr training

• AHERA and Lead certificate (Supervisor)• Attend two 8 hr courses on clan lab cleanup within 1st year• Attend 2 hr Refresher course on clan lab cleanup every year

thereafter• Oregon

– Sampling personnel• CIH or BS in Science working under OSHA, EPA or Industrial

Hygiene firm– Contractors and personnel

• State mandated training (pass test w/70% or greater)• Annual refresher course

• Washington– 2 day course for workers, additional day course for supervisors– Annual refresher

Article 7. Enforcement and LiabilityArticle 7. Enforcement and Liability• 25400.45

– PO who does not provide a notice or disclosure subject to $5K civil penalty AND full cost of all harm to public health or environment

– Person who violates this chapter prohibiting occupancy is subject to $5K civil penalty.

• 25400.45 – PO who does not provide a notice or

disclosure subject to $5K civil penalty AND full cost of all harm to public health or environment

– Person who violates this chapter prohibiting occupancy is subject to $5K civil penalty.

• 25400.46 – PO shall pay all the following if property found

contaminated:• cost of testing• cost of maintaining records regarding the property• cost of remediating the property• actual cost incurred by LHO from enforcement of this

chapter and oversight of the implementation of the PSA WP and PSA report

• A person who conducts meth activity on the property and who is not the owner of that property is liable for and shall reimburse the owner of the property for any cost the PO incurs above

• 25400.46 – PO shall pay all the following if property found

contaminated:• cost of testing• cost of maintaining records regarding the property• cost of remediating the property• actual cost incurred by LHO from enforcement of this

chapter and oversight of the implementation of the PSA WP and PSA report

• A person who conducts meth activity on the property and who is not the owner of that property is liable for and shall reimburse the owner of the property for any cost the PO incurs above

HEALTH AND SAFETY CODE SECTION 25400.10-25400.12 25400.10. (a) The Legislature finds and declares all of the following: (1) Methamphetamine use and production are growing throughout the state. Properties may be contaminated by hazardous chemicals used or produced in the manufacture of methamphetamine where those chemicals remain and where the contamination has not been remediated. (2) Initial cleanup actions may be limited to the removal of bulk hazardous materials and associated glassware that pose an immediate threat to public health and the environment. Where methamphetamine production has occurred, significant levels of contamination may be found throughout residential properties if the contamination is not remediated. (3) Once methamphetamine laboratories have been closed, the public may be harmed by the materials and residues that remain. (4) There is no statewide standardization of standards for determining when a site of a closed methamphetamine laboratory has been successfully remediated. (b) This chapter shall be known, and may be cited as, the "Methamphetamine Contaminated Property Cleanup Act of 2005." 25400.11. For purposes of this chapter, the following definitions shall apply: (a) "Authorized contractor" means a person who has been trained or received other qualifications pursuant to Section 25400.40. (b) "Contaminated" or "contamination" means property polluted by a hazardous chemical related to methamphetamine laboratory activities. (c) "Controlled substance" has the same meaning as defined in Section 11007. (d) "Decontamination" means the process of reducing the level of a known contaminant to a level that is deemed safe for human reoccupancy, as established pursuant to Section 25400.16 using currently available methods and processes. (e) "Department" means the Department of Toxic Substances Control. (f) "Designated local agency" means a city, county, or city and county agency designated by the local health officer to carry out all, or any portion of, responsibilities assigned to the local health officer as specified by this chapter. The local health officer may authorize any of the following to serve as a designated local agency: (1) The Certified Unified Program Agency or CUPA as certified pursuant to Chapter 6.11 (commencing with Section 25404), except in a jurisdiction where the state is acting as the CUPA pursuant to subdivision (f) of Section 25404.3. (2) The fire department or environmental health department. (3) The local agency responsible for enforcement of the State Housing Law (Part 1.5 (commencing with Section 17910) of Division 13). (g) "Disposal of contaminated property" means the disposal of property that is a hazardous waste in accordance with Chapter 6.5

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(commencing with Section 25100). (h) "Hazardous chemical" means a chemical that is determined by the local health officer to be toxic, carcinogenic, explosive, corrosive, or flammable that was used in the manufacture or storage of methamphetamine that is prohibited by Section 11383. (i) "Illegal methamphetamine manufacturing or storage site" or "site" means property where a person manufactures methamphetamine or stores methamphetamine or a hazardous chemical used in connection with the manufacturing or storage and in violation of Section 11383. (j) "Local health officer" means a county health officer, a city health officer, or an authorized representative of that local health officer. (k) "Methamphetamine laboratory activity" means the illegal manufacturing or storage of methamphetamine. (l) "Office" means the Office of Environmental Health Hazard Assessment. (m) "Posting" means attaching a written or printed announcement conspicuously on property that is determined to be contaminated by a methamphetamine laboratory activity or the storage of methamphetamine or a hazardous chemical. (n) "Preliminary site assessment work plan" or "PSA work plan" means a plan to conduct activities to determine the extent and level of contamination of an illegal methamphetamine manufacturing or storage site and that is prepared in accordance with the requirements of Section 25400.36. (o) "Preliminary site assessment" or "PSA" means the activities taken to determine the extent and level of contamination of an illegal methamphetamine manufacturing or storage site that are conducted in accordance with an approved PSA work plan. (p) "Preliminary site assessment report" or "PSA report" means a determination that the levels of contamination at an illegal methamphetamine manufacturing or storage site require remediation, including a recommendation for the remedial actions required for the site to meet human occupancy standards, and that is prepared in accordance with Section 25400.37. (q) (1) "Property" means any parcel of land, structure, or part of a structure where the manufacture of methamphetamine or storage of methamphetamine or a hazardous chemical that is prohibited by Section 11383, occurred, including, manufactured housing and mobilehomes. (2) Notwithstanding paragraph (1), "property" does not include any of the following: (A) A mobilehome park or manufactured housing park, as defined, respectively, in Section 798.4 or 798.6 of the Civil Code. (B) A manufactured housing community, as defined in Section 18801. (C) A mobilehome park or park, as defined, respectively, in Section 18214 or 18214.5. (D) A mobilehome or manufactured housing located in a mobilehome park, manufactured housing park, or manufactured housing community, or park, as defined in this paragraph. (3) Paragraph (2) shall become inoperative on January 1, 2008, unless a later enacted statute that is enacted before January 1, 2008, deletes or extends that date. (r) (1) "Property owner" means a person owning property by reason of obtaining it by purchase, exchange, gift, lease, inheritance, or legal action. (2) Notwithstanding paragraph (1), "property owner" does not include any of the following: (A) The manager or owner of a mobilehome park, manufactured



housing park, manufactured housing community, or park, as defined in paragraph (2) of subdivision (q). (B) An agent or representative authorized to act on behalf of a manager or owner specified in subparagraph (A). (C) A person who owns a mobilehome located in a mobilehome park, manufactured housing park, manufactured housing community, or park. (3) Paragraph (2) shall become inoperative on January 1, 2008, unless a later enacted statute that is enacted before January 1, 2008, deletes or extends that date. (s) "Storage site" means any property used for the storage of a hazardous chemical or methamphetamine that is prohibited by Section 11383. (t) "Warning" means a sign posted by the local health officer conspicuously on property where methamphetamine was manufactured or stored, informing occupants that hazardous chemicals exist on the premises and that entry is unsafe. 25400.12. Any term not defined expressly by this article shall have the same meaning as defined in Chapter 6.8 (commencing with Section 25300).



HEALTH AND SAFETY CODE SECTION 25400.16 25400.16. (a) Except as provided in subdivision (c), property contaminated by methamphetamine laboratory activity is safe for human occupancy for purposes of this chapter only if the level of methamphetamine on any indoor surface is less than, or equal to, 0.1 micrograms per 100 square centimeters. (b) Except as provided in subdivision (c), if property is contaminated by methamphetamine laboratory activity that included the use of lead or mercury compounds, in addition to the requirements of subdivision (a), property is safe for human occupancy for purposes of this chapter only if both of the following standards are met with regard to that property: (1) The total level of lead is less than, or equal to, 20 micrograms per square foot. (2) The level of mercury is less than, or equal to, 50 nanograms per cubic meter in air. (c) Subdivisions (a) and (b) shall become inoperative on the effective date that the department, in consultation with the office, adopts a health-based target remediation standard for methamphetamine to determine when a property contaminated by methamphetamine laboratory activity only is safe for human occupancy, in which case any reference in this chapter to a human-occupancy standard specified in this section shall mean only the health-based target remediation standard for methamphetamine adopted by the department. (d) The department shall conduct two public workshops, one in northern California and one in southern California, for the purpose of discussing with affected stakeholders the actions needed to further implement the goals of this chapter. The department may include, as topics for discussion, possible funding sources for local governments for the purposes of implementing this chapter, whether this chapter should be revised to address the contamination of properties by the illegal manufacturing of other controlled substances, and the results of the Illegal Drug Lab Risk Reduction Project conducted by the California Environmental Protection Agency pursuant to its adopted environmental justice action plan.

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HEALTH AND SAFETY CODE SECTION 25400.17-25400.22 25400.17. (a) Notwithstanding any other provision of law, a city, county, or city and county shall comply with the uniform regulations and standards established pursuant to this chapter. (b) A local health officer may delegate all or part of the duties specified in this chapter to a designated local agency. (c) If a methamphetamine laboratory activity has taken place at a property, the local health officer shall assume that the methamphetamine manufacturing process has led to some degree of chemical contamination and shall take action pursuant to this chapter. 25400.18. Within 48 hours after receiving notification from a law enforcement agency of potential contamination of property by a methamphetamine laboratory activity, the local health officer shall post a written notice in a prominent location on the premises of the property. At a minimum, the notice shall include all of the following information: (a) The word "WARNING" in large bold type at the top and bottom of the notice. (b) A statement that a methamphetamine laboratory was seized on or inside the property. (c) The date of the seizure. (d) The address or location of the property including the identification of any dwelling unit, room number, apartment number, or mobilehome or manufactured home identification number. (e) The name and contact telephone number of the agency posting the property. (f) A statement specifying that hazardous substances, toxic chemicals, or other hazardous waste products may have been present and may remain on or inside the property. (g) A statement that it is unlawful for an unauthorized person to enter the contaminated portion of the property until advised that it is safe to do so by the local health officer or designated local agency. (h) A statement that a person disturbing or destroying the posted notice is subject to a civil penalty in an amount of up to five thousand dollars ($5,000). (i) A statement that a person violating the posted notice is subject to a civil penalty in an amount of up to five thousand dollars ($5,000). 25400.19. Within five working days after receiving a notification from a law enforcement agency of known or suspected contamination of a property by a methamphetamine laboratory activity, or upon notification from the property owner, the local health officer shall inspect the property pursuant to this section. (a) The property inspection shall include, but not be limited to, obtaining evidence of hazardous chemical use or storage and documentation of evidence of any chemical stains, cooking activity



and release or spillage of hazardous chemicals used to manufacture methamphetamine. (b) In conducting an inspection pursuant to this section, the local health officer may request copies of any law enforcement reports, forensic chemist reports, and any hazardous waste manifests, to evaluate all of the following: (1) The length of time the property was used as an illegal methamphetamine manufacturing or storage site. (2) The extent of the property actually used and contaminated in the manufacture of methamphetamine or the storage of methamphetamine or a hazardous chemical. (3) The chemical process that was involved in the illegal methamphetamine manufacturing. (4) The chemicals that were removed from the scene. (5) The location of the illegal methamphetamine manufacturing or storage site in relation to the habitable areas of the property. 25400.20. (a) Upon completing an inspection pursuant to Section 25400.19, the local health officer shall immediately determine whether the property is contaminated. (b) If the local health officer determines the property is contaminated, the local health officer shall take the actions specified in Section 25400.22. (c) If the local health officer determines that the property is not contaminated, within three working days after making that determination, the local health officer shall remove all notices posted pursuant to Section 25400.18 and prepare a written documentation of this determination, which shall include all of the following: (1) Findings and conclusions. (2) Name of the property owner, and, if applicable, mailing and street address of the property, or vehicle identification number, if applicable. (3) Parcel identification number, if applicable. (d) Within 10 working days after preparing a written documentation of the determination made pursuant to subdivision (c) that the property is not contaminated, the local health officer shall send a copy of the documentation to the property owner, and to the local agency responsible for enforcement of the State Housing Law (Part 1.5 (commencing with Section 17910) of Division 13). 25400.22. (a) No later than 10 working days after the date when a local health officer determines that property is contaminated pursuant to subdivision (b) of Section 25400.20, the local health officer shall do both of the following: (1) If the property is real property, record with the county recorder a lien on the property. The lien shall specify all of the following: (A) The name of the agency on whose behalf the lien is imposed. (B) The date on which the property is determined to be contaminated. (C) The legal description and the assessor's parcel number. (D) The record owner of the property. (E) The amount of the lien, which shall be the greater of two hundred dollars ($200) or the costs incurred by the local health



officer in compliance with this chapter, including, but not limited to, the cost of inspection performed pursuant to Section 25400.20 and the county recorder's fee. (2) Issue to persons specified in subdivisions (d), (e), and (f) an order prohibiting the use or occupancy of the property. (b) The county recorder's fees for recording and indexing documents provided for in this subdivision shall be in the amount specified in Article 5 (commencing with Section 27360) of Chapter 6 of Part 3 of Title 3 of the Government Code. (c) The lien recorded pursuant to subdivision (a) shall have the force, effect, and priority of a judgment lien. The local health officer shall not release the lien until either of the following occurs: (1) The property owner satisfies the lien and the local health officer issues a release pursuant to Section 25400.27. (2) The lien is otherwise released under applicable law. (d) Except as otherwise specified in this section, an order issued pursuant to this section shall be served, either personally or by certified mail, return receipt requested, to all known occupants of the property and to all persons who have an interest in the property, as contained in the records of the recorder's office of the county in which the property is located. (e) If the whereabouts of the person described in subdivision (d) are unknown and cannot be ascertained by the local health officer, in the exercise of reasonable diligence, and the local health officer makes an affidavit to that effect, the local health officer shall serve the order by personal service or by mailing a copy of the order by certified mail, postage prepaid, return receipt requested, as follows: (1) The order shall be served to each person at the address appearing on the last equalized tax assessment roll of the county where the property is located, and to all occupants of the affected unit. (2) The order shall be served at the address contained in the record of the county recorder. (f) The local health officer shall also mail a copy of the order required by this section to the address of each person or party having a recorded right, title, estate, lien, or interest in the property and to the association of a common interest development, as defined in Section 1351 of the Civil Code. (g) The order issued pursuant to this section shall include all of the following information: (1) A description of the property. (2) The parcel identification number, if applicable. (3) The vehicle identification number, if applicable. (4) A description of the local health officer's intended course of action. (5) A specification of the penalties for noncompliance with the order. (6) A prohibition on the use of all or portions of the property that are contaminated. (7) A description of the measures the property owner is required to take to decontaminate the property. (8) An indication of the potential health hazards involved. (9) A statement that a property owner who fails to provide a notice or disclosure that is required by this chapter is subject to a civil penalty of up to five thousand dollars ($5,000). (h) The local health officer shall provide a copy of the order to the local building or code enforcement agency or other appropriate agency responsible for the enforcement of the State Housing Law (Part



1.5 (commencing with Section 17910) of Division 13). (i) The local health officer shall post the order in a conspicuous place on the property within one working day of the date that the order is issued.



HEALTH AND SAFETY CODE SECTION 25400.25-25400.28 25400.25. (a) A property owner who receives an order issued pursuant to Section 25400.22 that property owned by that person is contaminated by a methamphetamine laboratory activity, a property owner who owns property that is the subject of an order posted pursuant to subdivision(i) of Section 25400.22, and a person occupying property that is the subject of the order, shall immediately vacate the affected unit that is determined to be in a hazardous zone by the local health officer. (b) No later than 30 days after receipt of an order issued pursuant to Section 25400.22, the property owner shall demonstrate to the local health officer that the property owner has retained a methamphetamine laboratory site remediation firm that is an authorized contractor to remediate the contamination caused by the methamphetamine laboratory activity. 25400.26. (a) A property owner who receives an order issued pursuant to Section 25400.22 that property owned by that person is contaminated by a methamphetamine laboratory activity, or a property owner who owns property that is the subject of an order posted pursuant to subdivision (i) of Section 25400.22, shall utilize the services of an authorized contractor to remediate the contamination caused by the methamphetamine laboratory activity, in accordance with the procedures specified in this section. (b) The property owner and the local health officer shall keep all required records documenting decontamination procedures for three years following certification that the property is habitable. (c) The property owner or the property owner's authorized contractor shall submit a preliminary site assessment work plan to the local health officer for review no later than 30 days after demonstrating to the local health officer that an authorized contractor has been retained to remediate the contamination caused by the methamphetamine laboratory activity. (d) (1) No later than 10 working days after the date the PSA work plan is submitted by the property owner, the local health officer shall review the PSA work plan to determine whether the PSA work plan complies with this chapter, including the procedures established pursuant to Section 25400.35. (2) If there are any deficiencies in a submitted PSA work plan, the local health officer shall inform the property owner and authorized contractor, in writing, of those deficiencies no later than 15 days of the date that the PSA work plan was submitted to the local health officer. (3) If the local health officer approves the plan, the local health officer shall inform in writing, the property owner and authorized contractor no later than 15 days of the date that the PSA work plan was submitted to the local health officer. (e) (1) After a PSA is completed in accordance with the PSA work plan, the property owner and authorized contractor shall prepare a PSA report in accordance with Section 25400.37 and submit the PSA report to the local health officer. (2) If after a PSA is completed in accordance with a PSA work



plan, and the local health officer, upon review of the PSA report, determines there is no level of contamination at a site that requires remediation, the local health officer shall take the actions specified in Section 25400.27. (f) The property owner shall complete remediation of all applicable portions of the contaminated property in accordance with this chapter no later than 90 days after the date that the PSA work plan has been approved by the local health officer. The local health officer may extend the date for completion of the remediation, in writing. 25400.27. (a) If a local health officer determines that property that has been the subject of a PSA report has been remediated in accordance with this chapter, or if the local health officer makes the determination specified in paragraph (2) of subdivision (e) of Section 25400.26, the local health officer shall issue a no further action determination. (b) For real property, within 10 working days of the date of making the determination or of receiving payment for the amount of the lien recorded pursuant to paragraph (1) of subdivision (a) of Section 25400.22, whichever is later, the local officer shall do both of the following: (1) Release the lien recorded with the county recorder. The release shall specify all of the following: (A) The name of the agency on whose behalf the lien is imposed. (B) The recording date of the lien being released. (C) The legal description and the assessor's parcel number. (D) The record owner of the property. (E) The recording instrument, or book and page, of the lien being released. (2) Send a copy of the release stating that the property was remediated in accordance with this chapter, does not violate the standard for human occupancy established pursuant to this chapter, and is habitable, to the property owner, local agency responsible for the enforcement of the State Housing Law (Part 1.5 (commencing with Section 17910) of Division 13), and all recipients pursuant to this section and Section 25400.22. 25400.28. Until a property owner subject to Section 25400.25 receives a notice from a local health officer pursuant to Section 25400.27 that the property identified in an order requires no further action, all of the following shall apply to that property: (a) Except as otherwise required in Section 1102.3 or 1102.3a of the Civil Code, the property owner shall notify the prospective buyer in writing of the pending order, and provide the prospective buyer with a copy of the pending order. The prospective buyer shall acknowledge, in writing, the receipt of a copy of the pending order. (b) The property owner shall provide written notice to all prospective tenants that have completed an application to rent an affected dwelling unit or other property of the remediation order, and shall provide the prospective tenant with a copy of the order. The prospective tenant shall acknowledge, in writing, the receipt of the notice and pending order before signing a rental agreement. The notice shall be attached to the rental agreement. If the property owner does not comply with this subdivision, the prospective tenant may void the rental agreement.





HEALTH AND SAFETY CODE SECTION 25400.30 25400.30. (a) If a property owner does not initiate or complete the remediation of property in compliance with an order issued by a local health officer pursuant to this chapter, the city, county, or city and county in which the property is located may, at its discretion, take action to remediate the residually contaminated portion of the property pursuant to this chapter or may seek a court order to require the property owner to remediate the property in compliance with this chapter. (b) If a local health officer is unable to locate a property owner within 10 days after the date the local health officer issues an order pursuant to Section 25400.22, the city, county, or city and county in which the property is located may remediate the property in accordance with this article. The city or county or its contractors may remove contaminated property as part of this remediation activity. (c) If a city, county, or city and county elects to remediate contaminated property pursuant to this article, the property owner is liable for, and shall pay the city or county for, all actual costs related to the remediation, including, but not limited to, all of the following: (1) Posting and physical security of the contaminated site. (2) Notification of affected people, businesses or any other entity. (3) Actual expenses related to the recovery of cost, laboratory fees, cleanup services, removal costs, and administrative and filing fees. (d) If a property owner does not pay the city, county, or city and county for the costs of remediation specified in subdivision (c), the city, county, or city and county may record a nuisance abatement lien pursuant to Section 38773.1 of the Government Code against the property for the actual costs related to the remediation or bring an action against the property owner for the remediation costs. The nuisance abatement lien shall have the effect, priority, and enforceability of a judgment lien from the date of its recordation.

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HEALTH AND SAFETY CODE SECTION 25400.35-25400.40 25400.35. A local health officer shall establish a written plan consistent with this chapter outlining the procedures to be followed for conducting the remediation to property for purposes of this chapter. The procedures shall comply with this article and any regulations adopted pursuant to this chapter, and shall include, but not be limited to, procedures for the preparation of a preliminary site assessment work plan, the conduct of a preliminary site assessment to determine the extent and level of contamination, in accordance with that PSA work plan, and the preparation of a PSA report containing the results of the preliminary site assessment and recommendations for remediation to meet the occupancy standards specified in Section 25400.16. 25400.36. The PSA work plan shall include, but is not limited to, all of the following: (a) The physical location of the property. (b) A summary of the information obtained from law enforcement, the local health officer, and other involved local agencies. The summary shall include a discussion of the information's relevance to the contamination, including areas suspected of being contaminated, and may include all of the following information: (1) Duration of laboratory operation and number of batches cooked or processed. (2) Hazardous chemicals known to have been manufactured. (3) Recipes and methods used. (4) Chemicals and equipment found, by location, used in connection with the manufacture or storage of the hazardous chemicals. (5) Location of contaminated cooking and storage areas. (6) Visual assessment of the severity of contamination inside and outside of the structure where the laboratory was located. (7) Assessment of contamination of adjacent rooms, units, apartments, or structures. (8) Disposal methods observed at or near the site, including dumping, burning, burial, venting, or drain disposal. (9) A comparison of the chemicals on the manifest with known methods of manufacture in order to identify other potential contaminants. (10) A determination as to whether the methamphetamine manufacturing method included the use of chemicals containing mercury or lead, including lead acetate, mercuric chloride, mercuric nitrate. (c) A description of the areas to be sampled and the basis for the selection of the areas. This element of the PSA work plan shall also document the decision process used in determining not to sample particular areas. The PSA work plan shall consider both primary and secondary areas of concern. (1) The primary areas of concern included in the work plan shall include all the following areas: (A) Any area that has obvious staining caused by the use or manufacture of hazardous chemicals.



(B) Any processing or cooking area, with contamination caused by spills, boilovers, explosions, or by chemical fumes and gases created during cooking. The area may include floors, walls, ceilings, glassware, and containers, working surfaces, furniture, carpeting, draperies and other textile products, plumbing fixtures and drains, heating and air-conditioning vents. (C) Any disposal area, including such indoor areas as sinks, toilets, bathtubs, plumbing traps and floor drains, vents, vent fans, and chimney flues and such outdoor areas that may be contaminated by dumping or burning on or near soil, surface water, groundwater, sewer or storm systems, septic systems, and cesspools. (D) Chemical storage areas that may be contaminated by spills, leaks, or open containers. (2) The secondary areas of concern shall include all of the following: (A) Any location where contamination may have migrated, including hallways or other high traffic areas. (B) Common areas in multiple dwellings, and adjacent apartments or rooms, including floors, walls, ceilings, furniture, carpeting, light fixtures, blinds, draperies and other textile products. (C) Common ventilation or plumbing systems in hotels and multiple dwellings. (d) Sampling protocols, analytical methods and laboratories to use and their relevant certifications or accreditations. (e) A description of areas and items that will be remediated in lieu of sampling, if any. 25400.37. After a preliminary site assessment is completed in accordance with the PSA work plan, a PSA report shall be prepared and submitted to the local health officer. The PSA report shall be thorough and specific in reporting findings and recommendations and shall include all of the following: (a) The location of the site, including the street address and mailing address of the contaminated property, the owner of record and mailing address, legal description, and clear directions for locating the property. (b) A site map, including a diagram of the contaminated property. The diagram shall include floor plans of affected buildings and local drinking water wells and nearby streams or other surface waters, if potentially impacted, and shall show the location of damage and contamination and the location of sampling points used in the preliminary site assessment. All sampling point locations shall be keyed to the sampling results and remediation recommendations. (c) A description of the sampling methods and analytical protocols used in the preliminary site assessment. (d) A description of the sampling results. (e) Information regarding the background samples and results obtained. (f) Specific recommendations, including methods, for remedial actions required to meet the human occupancy standards specified in Section 25400.16, including, but not limited to, any required decontamination, demolition, or disposal. (g) A plan for postremediation site assessment, including specific sampling requirements and methodologies, and locations at which samples are to be obtained. 25400.38. The PSA work plan and PSA report shall be signed and



notarized by the contractor responsible for the completion of the preliminary site assessment and by a certified industrial hygienist for sufficiency and completeness. 25400.40. (a) A person shall not perform a preliminary site assessment or any remediation work pursuant to this chapter, including a decontamination, demolition, or disposal, unless the person has completed all of the following: (1) Initial training pursuant to subparagraph (A) of paragraph (3) of, or paragraph (4) of, subdivision (e) of Section 5192 of Title 8 of the California Code of Regulations, as applicable. That training shall include elements listed pursuant to subparagraphs (A) to (G), inclusive, of paragraph (2) of subdivision (e) of Section 5192 of Title 8 of the California Code of Regulations. (2) Annual refresher training pursuant to paragraph (8) of subdivision (e) of Section 5192 of Title 8 of the California Code of Regulations. (3) Additional requirements as determined by the local health officer, or other applicable law. (b) Training specified in paragraphs (1) and (2) of subdivision (a) shall be certified pursuant to paragraph (6) of subdivision (e) of Section 5192 of Title 8 of the California Code of Regulations.



HEALTH AND SAFETY CODE SECTION 25400.45-25400.46 25400.45. (a) A property owner who does not provide a notice or disclosure required by this chapter is subject to a civil penalty in an amount of up to five thousand dollars ($5,000). A property owner shall also be assessed the full cost of all harm to public health or to the environment resulting from the property owner's failure to comply with this chapter. (b) A person who violates an order issued by a local health officer pursuant to this chapter prohibiting the use or occupancy of a property contaminated by a methamphetamine laboratory activity is subject to a civil penalty in an amount of up to five thousand dollars ($5,000). 25400.46. (a) A property owner who receives an order issued by a local health officer pursuant to Section 25400.22, or a property owner who owns property that is the subject of a notice posted pursuant to subdivision (i) of Section 25400.22, is liable for, and shall pay all of the following costs if it is determined that the property is contaminated: (1) The cost of any testing. (2) Any cost related to maintaining records with regard to the property. (3) The cost of remediating the property, including any decontamination or disposal expenses. (4) Any actual cost incurred by the local health officer or any other local or state agency resulting from the enforcement of this chapter and oversight of the implementation of the PSA work plan and the PSA report, with regard to that property. (b) A person who conducts a methamphetamine laboratory activity on or at property, and who is not the owner of that property, is liable for, and shall reimburse the owner of the property for, any cost the property owner may incur pursuant to subdivision (a).



IntroductionC

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Sam

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Sacramento County Environmental Management Department

PLAN FOR THE ASSESSMENT AND REMEDIATION OF PROPERTIES

CONTAMINATED BY METHAMPHETAMINE LABORATORY ACTIVITIES

Hazardous Materials Division 8475 Jackson Road, Suite 240 Sacramento, California 95826

JANUARY 2006

Plan for the Assessment and Remediation Sacramento County EMD of Properties Contaminated by Methamphetamine Laboratory Activities

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COUNTY OF SACRAMENTO ENVIRONMENTAL MANAGEMENT DEPARTMENT

--- PLAN FOR THE ASSESSMENT AND REMEDIATION

OF PROPERTIES CONTAMINATED BY METHAMPHETAMINE LABORATORY ACTIVITIES

1.0 INTRODUCTION .................................................................................................................2 2.0 AUTHORITY ........................................................................................................................2 3.0 DETERMINATION OF CONTAMINATION AND NOTIFICATION PROCEDURES.............2 4.0 PROPERTY RESTRICTIONS .............................................................................................3 5.0 PROPERTY OWNER RESPONSIBILITIES ........................................................................4 6.0 REMEDIATION PROCESS - Preliminary Site Assessment (PSA) ......................................4 6.1 PSA WORK PLAN .........................................................................................................4 6.2 PSA REPORT................................................................................................................6 7.0 SAMPLING PROTOCOL .....................................................................................................7 7.1 WIPE SAMPLES AND RESULT REPORTING..............................................................7 7.2 COMPOSITE SAMPLES................................................................................................8 8.0 GROSS REMEDIATION ......................................................................................................8 9.0 RESIDUAL REMEDIATION .................................................................................................8 9.1 AIRING-OUT/VENTING.................................................................................................9 9.2 AIR MONITORING.........................................................................................................9 9.3 REMOVAL....................................................................................................................10 9.4 SURFACE WASHING..................................................................................................10 9.5 ENCAPSULATION.......................................................................................................10 9.6 VENTILATION SYSTEM..............................................................................................11 9.7 IMPACTED SOIL AND GROUNDWATER...................................................................11 10.0 POST REMEDIATION ASSESSMENT.............................................................................12 11.0 FINAL REPORT................................................................................................................12 11.1 TWO OPTIONS FOR COMPLETION ..........................................................................12 11.2 REPORT COMPONENTS ...........................................................................................12 12.0 NO FURTHER ACTION (NFA) DETERMINATION ..........................................................13 13.0 REOCCUPANCY CRITERIA ............................................................................................13 13.1 METHAMPHETAMINE.................................................................................................13 13.2 LEAD AND MERCURY................................................................................................13 14.0 ANALYTICAL AND SAMPLING METHODS.....................................................................13 15.0 LABORATORY REQUIREMENTS ...................................................................................14 16.0 WASTE DISPOSAL ..........................................................................................................14 17.0 SEPTIC SYSTEMS...........................................................................................................15 ATTACHMENT I – The Surrogate Method .................................................................................16 ATTACHMENT II – Chemicals of Concern .................................................................................21 ATTACHMENT III - Resources ...................................................................................................22


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1.0 INTRODUCTION 1.1 Clandestine laboratories which illegally manufacture methamphetamine (Clan Labs) are periodically discovered in Sacramento County and subsequently seized by law enforcement personnel. While officials arrange for the removal of chemicals and process equipment for evidence, portions of, or the entire property may be highly contaminated with both precursor chemicals and the final drug products. 1.2 As required by Section 25400.35 of Chapter 6.9.1 of the California Health and Safety Code (H&SC), this Plan has been developed to establish procedures for the assessment and remediation of clandestine methamphetamine manufacturing sites within Sacramento County. These procedures are to be followed by property owners and authorized contractors to develop and implement an appropriate remediation strategy, and by County authorities to evaluate workplans and assessments in a manner consistent with best available practices. 1.3 This Plan has been peer-reviewed by other County health and environmental agencies within the State of California, as well as technical experts in the Clan Lab remediation industry and is consistent with Chapter 6.9.1, Article 6 of the H&SC.

2.0 AUTHORITY Pursuant to Chapter 6.9.1, Section 25400.17(b) of the California Health and Safety Code (H&SC), the Sacramento County Health Officer has delegated authority for the regulatory oversight of these contaminated properties to the Sacramento County Environmental Management Department (EMD).

3.0 DETERMINATION OF CONTAMINATION AND NOTIFICATION PROCEDURES

3.1 Upon notification from law enforcement or other sources that a Clan Lab has been discovered, EMD will:

3.1.1 Respond and post the property in a conspicuous location within 48 hours after notification. EMD may not limit posting to the room where the cooking occurred (e.g., bedroom, kitchen) within the occupancy; experience has indicated that contamination is rarely limited to the specific area of the cooking process. Depending upon the apparent extent of contamination, EMD may post adjacent units of apartments, hotels, and other proximal building units. If the clan lab activity has been limited to outbuildings such as sheds and garages, these may be posted without impacting the residence. Anyone disturbing or destroying the posted notice is subject to a civil penalty in an amount of up to five thousand dollars ($5,000).


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3.1.2 Perform an inspection of the property and surrounding area within five (5) days after notification. The inspection will include, but not be limited to: obtaining evidence of hazardous chemical use or storage and documentation of evidence of any chemical stains, cooking activity and release or spillage of hazardous chemicals used in the production of methamphetamine.

3.2 If EMD determines that the property is not contaminated, EMD will complete the following actions:

3.2.1 Within three (3) working days of making the determination, remove all notices posted to the property and prepare written documentation that includes findings and conclusions. 3.2.2 Within ten (10) working days after preparing written documentation that the property is not contaminated, send a copy of this document to the property owner and to the local code enforcement agency that has jurisdiction.

3.3 If EMD determines that the property is contaminated, EMD will complete the following actions within ten (10) working days after making the determination.

3.3.1 If the property is real property, record with the Sacramento County Clerk Recorder’s office a lien on the property. 3.3.2 Issue an Order to all known occupants of the property and to all persons who have a recorded right, title, estate, lien, or interest in the property prohibiting use or occupancy of the property.

3.3.2(a). Provide a copy of the Order to local code enforcement that has jurisdiction. 3.3.2(b). Within one working day of the issuance of the Order, post a copy in a conspicuous place on the property.

4.0 PROPERTY RESTRICTIONS 4.1 Properties used as Clan Labs will typically be found with a lab-like setting, including containers of chemicals and manufacturing equipment. While this material will be removed by a law enforcement sponsored contractor, EMD experience indicates that, until proven otherwise, contamination from the drug manufacturing process remains. Typical areas of contamination include sinks, toilets, bathtubs, floor, walls, ceilings, carpets, drapes, furniture and ventilation (heating and air conditioning) systems. 4.2 Entry into the posted area(s) of the property is prohibited unless specifically approved in writing by EMD. 4.3 No personal belongings, furniture, or other items will be removed from the tagged property until released by EMD. Such release is not likely to occur until the Preliminary Site Assessment (PSA) has been reviewed and approved by EMD.


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4.4 Anyone completing an unauthorized entry or removal is subject to a civil penalty in an amount of up to five thousand dollars ($5,000).

5.0 PROPERTY OWNER RESPONSIBILITIES 5.1 A property owner and any person(s) occupying the property that is the subject of an Order issued per paragraph 3.2.1 above, shall immediate vacate the affected unit described in the Order (H&SC Section 25400.25(a)). 5.2 The property owner shall utilize the services of an “authorized contractor” (H&SC Section 25400.26(a)) to remediate the contamination and shall, within 30 days after receipt of an Order, demonstrate to EMD that such an authorized contractor has been retained for this work. An “authorized contractor” means a person who has been trained or received other qualifications pursuant to Section 25400.40 of the H&SC. 5.3 The property owner or the property owner’s authorized contractor shall submit a preliminary site assessment (PSA) Work plan to EMD for review. This shall be submitted no later than 30 days after demonstrating to EMD that an authorized contractor has been retained by the property owner. 5.4 The property owner shall complete remediation of all applicable portions of the contaminated property in accordance with H&SC Chapter 6.9.1 no later than 90 days after the date that the PSA Work Plan has been approved by EMD. 5.5 Until the property owner receives a determination from EMD that no further action is required to remediate the affected units or site, the following must be complied with:

5.5.1 All prospective buyers of the property shall be provided with a copy of the Order and must indicate receipt in writing. 5.5.2 All prospective tenants that have completed an application to rent an affected unit or other property described on the Order shall be provided with a copy of the Order and must indicate receipt in writing.

6.0 REMEDIATION PROCESS – Preliminary Site Assessment (PSA)

6.1 PSA Work Plan. A written PSA Work Plan shall be developed and submitted to EMD within 30 days after demonstrating to EMD that an authorized contractor has been retained by the property owner. The PSA Work Plan shall include, but not be limited to: 6.1.1 A description of the physical location of the property. 6.1.2 A summary of the information obtained from law enforcement, EMD, and any


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other involved agency. The summary shall include a discussion of the information’s relevance to the contamination, including areas suspected of being contaminated and may include all of the following:

6.1.2(a) Duration of lab operation and number of batches cooked and processed. 6.1.2(b) Hazardous chemicals known to have been manufactured at the site. 6.1.2(c) Recipes and methods use for methamphetamine production. Each type of methamphetamine manufacturing process involves chemicals specific to the process. The Red Phosphorus Method is the most common method found in Sacramento County. However, some clan labs have been discovered that used

the Ammonia Method (also known as the Birch or Nazi method). Information regarding process-specific chemicals is provided in Attachment II.

6.1.2(d) Chemicals and equipment and their location(s). 6.1.2(e) Location of contaminated cooking and storage areas. 6.1.2(f) Visual assessment of the severity of contamination inside and outside of the structure where the clan lab was discovered. 6.1.2(g) Assessment of any contamination in adjacent rooms, units, apartments or structures. 6.1.2(h) Disposal methods observed at or near the property (e.g. dumping, burning, burial, venting, and/or drain disposal). 6.1.2(i) A comparison of the chemicals on the manifest with known methods of manufacture in order to identify other potential contaminants. 6.1.2(j) A determination as to whether the manufacturing method included the

use of chemicals containing mercury or lead (e.g., lead acetate, mercuric chloride, mercuric nitrate).

6.1.3 A description of the areas to be sampled and the basis for the selection of the areas. This element of the work plan should also document the decision process used in determining not to sample particular areas. When identifying potential sample areas, consideration should be given to: 6.1.3(a) Obviously stained areas. 6.1.3(b) Areas in the immediate vicinity of the manufacturing (cooking) location. 6.1.3(c) Areas where chemicals were found. 6.1.3(d) Adjacent rooms. 6.1.3(e) Locations typically accessible for contact by occupants, particularly children. 6.1.3(f) High traffic areas outside of the cooking area. 6.1.3(g) Ventilation systems. 6.1.3(h) Hard and soft surfaces, walls, floors, ceilings and appliances. 6.1.3(i) Areas of potential waste disposal such as sinks, floor drains, bathtubs, showers, and toilets. 6.1.3(j) Septic systems (see Section 17.0).

6.1.4 Primary areas of potential contamination. 6.1.4(a) Manufacturing or cooking areas. Contamination in these areas can

be caused by spills, boil-over, explosions, or by chemical fumes and gases created during cooking. Affected areas include: floors, walls, ceilings, glassware, containers, working surfaces, furniture, carpeting, draperies and other textile products, plumbing fixtures and drains, heating and air conditioning vents.


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6.1.4(b) Disposal areas. Indoor areas include sinks, toilets, bathtubs, plumbing traps and floor drains, vents and vent fans, and chimney flues. Outdoor contamination may be caused by dumping or burning on or near soil, surface water, groundwater, sewer or storm systems, septic systems, and cesspools.

6.1.5 Secondary areas of potential contamination. 6.1.5(a) Locations where contamination may have migrated, such as hallways

or high-traffic areas. 6.1.5(b) Common areas in multiple dwellings, and adjacent apartments or

rooms, including floors, walls ceilings, furniture, carpeting, light fixtures, blinds, draperies and other textile products.

6.1.5(c) Common ventilation and plumbing systems in hotels and multiple dwellings.

6.1.6 Sampling protocols (Section 7.0), analytical methods (Section 14.0), laboratories to be used and their relevant certifications/accreditations. During each phase of sample collection, identical methods must be used to provide a common basis for comparing results.

6.1.7 A description of areas and items that will be remediated in lieu of sampling, if any. In the case of surfaces that are obviously or highly suspected to be contaminated, EMD will waive sampling requirements for those items or materials that will be removed and properly disposed. For example, if cooking was conducted in a kitchen and staining is evident, the property owner may decide that it is more cost-effective to remove and dispose of sheet rock, cabinets, appliances and linoleum rather than to spend money on sampling only to affirm that the materials are in fact contaminated. It may also be decided to surface wash (Section 9.4) and encapsulate (Section 9.5) all surfaces in a room that appear to have been impacted; assessment sampling would not be required for these surfaces, but post-remediation sampling would be. Note that the disposal facility may require sampling of these items or materials, an action over which EMD has no control.

6.1.8 The PSA work plan shall be signed and notarized by the contractor responsible for the completion of the PSA and by a Certified Industrial Hygienist (CIH).

6.2 PSA Report. After the PSA is completed, a PSA Report shall be prepared and submitted to EMD.

6.2.1 The PSA Report must be thorough and specific in reporting findings and recommendations. If areas or items are contaminated, the report must clearly specify all required remediation actions. Therefore, a recommendation such as “The stove and all adjacent impacted areas must be cleaned” is insufficient, for it begs the question of what constitutes an “adjacent impacted area.” It is important that the PSA sampling program is designed to provide sufficient data to make specific, rather than vague, recommendations. 6.2.2 Components of the PSA Report shall include: 6.2.2(a) Location which should include street address, mailing address, unit or

room number of the contaminated property. Also include the legal description, and clear directions for locating the property.

6.2.2(b) Owner of record, his/her mailing address, 6.2.2(c) Site map of the contaminated property, including floor plans of

affected buildings, local drinking water wells and nearby streams (if potentially


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impacted) drawn to a scale of 1/4” to 1’ unless otherwise directed by EMD. The diagram shall show the location of damage and contamination and the location of sampling points used in the PSA; the sampling point locations shall be keyed to the sampling results and remediation recommendations. 6.2.2(d) A description of the sampling methods and analytical protocols used in the assessment. 6.2.2(e) A description of the sampling results. If providing a narrative, group results by location rather than by analyte. Also include information regarding the background samples and results obtained. 6.2.2(f) Specific recommendations, including methods, for remedial actions required to meet State Re-occupancy Criteria (Section 13.0). 6.2.2(g) A plan for the Post Remediation Site Assessment, including specific sampling requirements and methodologies, and locations at which samples are to be obtained.

6.2.3 The PSA Report shall be signed and notarized by the authorized contractor responsible for the remediation work and by a Certified Industrial Hygienist (CIH). 6.2.4 If EMD upon review of the PSA Report determines that there is no level of contamination at the site that requires remediation, then EMD shall take actions specified in Section 12.0 of this Plan.

7.0 SAMPLING PROTOCOL EMD has reviewed a several sampling methods from a variety of sources, and has determined that a standard method based on the “Proposed Surrogate Method” devised by Bruce Lazarus, CIH, will be the benchmark for evaluating sampling protocols. Lazarus’ paper describing this method was published in the Journal of Clandestine Laboratory Investigating Chemists, Volume 10, Number 2. A brief review of Lazarus’ perspective, taken from the article, as well as the “Surrogate Method” sampling protocol required by EMD is at Attachment I.

7.1 WIPE SAMPLES AND RESULT REPORTING

7.1.1 Wipe samples are, at best, an imprecise sampling technique for which there is little agreement on the “best” method. It is noted that the literature indicates that wipe samples do not collect anywhere near all of the contaminant from a specific sampling area, and that it takes at least three wipes to collect the majority of the surface contamination. To control variables, the Consultant shall use a consistent wipe sample technique throughout the project, and describe the specific wipe sample process in the reports. EMD expects Consultants to follow the sample collection methodology described in Attachment I. 7.1.2 Recent work by the Washington Department of Ecology suggests that deionized water is not effective in lifting methamphetamine from sampled surfaces. Samples obtained using methanol as a solvent have shown much better recovery. Therefore, all wipe samples shall use methanol as the wetting/collecting solvent. Consultants are cautioned to use appropriate personal protective equipment when using methanol. 7.1.3 EMD will not accept sample results for which the area of the sample is not recorded. All methamphetamine wipe sample results shall be reported as weight/surface area, in mass/100cm2 (mass/ft2 for lead). A common investigation


8

practice is to take several swipes of unknown and inconsistent surface areas for a composite sample; such practices will not be accepted, even if only to substantiate that contamination exists in a particular area.

7.1.4 Lazarus recommends a one square foot surface area sample be obtained (see Attachment I). For general wipe sampling, literature and regulatory agencies typically recommend surface areas of either 100 cm2 or 1 ft2. EMD requires a surface sample area of 100 cm2, as this is consistent with other regulatory agencies for Clan Lab investigations. 7.1.5 Sample containers shall be bottles, as described in Attachment I. The use of plastic bags presents a greater opportunity for the contaminant to transfer from the wipe to the bag than would be the case with a bottle. In most instances, the laboratory will prepare the samples for analysis in the sample containers, allowing any sample transferred to the container wall to be collected.

7.2 COMPOSITE SAMPLES

7.2.1 Compositing of samples is a popular means of minimizing analytical costs. However, appropriate sampling and result reporting methods must be followed. In addition, care must be taken when deciding to composite, for a positive lab result may require individual re-sampling of all surfaces represented by that composite sample. Therefore, it is highly recommended that composite samples be reserved for those areas, in the authorized contractor’s judgment, are anticipated not to be contaminated. 7.2.2 Each sample area composited must be 100 cm2. For example, to composite wipe samples of four discrete wall areas in a kitchen, there must be four-100 cm2 wipes. Each wipe sample will be done with a #40 Whatman Filter Paper or similar (see Note to Attachment I), with compositing accomplished by the lab in the extraction process. The maximum number of wipe samples that may be composited is four. 7.2.3 Do not use composite sampling combining an area or item that is likely to be contaminated (e.g., obvious staining) with areas unlikely to show contamination (e.g., remote from known cooking areas). EMD will assume an attempt to dilute the sample from the likely contaminated areas to below instrument detection limits. Composite sampling should be limited to similar surfaces (i.e. walls with walls, etc.). 7.2.4 There should be no between-appliance compositing (e.g., stove AND refrigerator AND microwave). The authorized contractor may consider compositing samples within an appliance (e.g., in a stove: burners, oven, handles, knobs, surface, etc.), but defining 100 cm2 sample areas will be difficult.

8.0 GROSS REMEDIATION Materials associated with the operating Clan Lab, such as containers of chemicals and lab equipment, should have been removed by the law enforcement sponsored contractor at the time the lab was seized. If the authorized contractor finds any such materials during the site assessment process, the material should be left in place and the EMD shall be notified immediately.


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9.0 RESIDUAL REMEDIATION A number of processes can be successfully used to make the property suitable for re-occupancy. Note that the degree to which areas adjoining a space used for cooking activities are significantly contaminated is difficult to predict; long-term or high volume activities are likely to have impacted adjoining areas. As a result, it is generally most cost effective to assume low-level contamination by non-volatile materials and rid these and other areas of all potentially contaminated porous materials or items. Such decisions are to be reflected in the PSA Report. All material disposal associated with the site remediation process shall be in accordance with Section 16.0 “Waste Disposal.”

9.1 “AIRING-OUT”/VENTING. “Airing-out” is typically conducted by law enforcement personnel during lab processing. Several agencies have advocated the airing-out of a structure during the remediation process as a means to reduce the concentration of volatile solvents and similar materials by volatilization; some have suggesting increasing the air temperature within the structure to 85°F while increasing the ventilation rate for several days prior to remediation. While this practice may well reduce the airborne concentration of solvents and minimize the risk to remediation personnel, EMD does not accept it as a substitute for removing and disposing those items such as porous furnishings and wallboard that have been soaked or otherwise degraded/impacted by solvents.

9.2 AIR MONITORING. Several references and jurisdictions suggest the use of air monitoring for both evaluation of a property and for final clearance. EMD neither supports nor encourages the use of air monitoring, for the following reasons:

9.2.1 For many precursor and waste materials, validated analytical methods do not exist. For materials which have appropriate analytical methods, industrial hygiene sampling methods may not yield a low enough detection limit for evaluation against suggested exposure limits, requiring the use of expensive ambient air monitoring equipment. Direct reading instruments are generally non-specific and have relatively high detection limits. 9.2.2 Exposure limits for residential occupancies are problematic. Exposure limits established for occupational settings (e.g., PELs, TLVs, RELs) are inappropriate, as they are designed to protect, to some limited extent, the working population, not the more sensitive members of the population. 9.2.3 Exposure limits for ambient air, such as California OEHHA’s Toxic Hot Spot limits and the draft Clan Lab clearance limits developed by other states, are based on assumptions that make them far too low for practical use. For example, Colorado assumes occupancy 350 days a year, 24 hours a day, for 30 years. Implicit here is the assumption that the vapor source is steady-state, which would require it to be renewed. The lab is gone, chemicals removed, so a steady-state assumption fails. 9.2.4 The materials that air monitoring would detect are mostly volatile solvents, and most with vapor pressures above 10 torr. As long as the building has reasonable


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ventilation, the concentrations should decrease to negligible in a fairly short period of time. 9.2.5 Air monitoring may suggest that there is a problem, but provides no idea where to look for it. The effort may be better placed in additional wipe and bulk samples.

9.3 REMOVAL

9.3.1 Visibly contaminated (etched or stained) sinks, bathtubs, toilets and similar fixtures are to be removed and properly disposed. 9.3.2 Porous materials (e.g., carpeting, suspended ceiling panels, wallpaper, etc.) that can absorb dust, powder, aerosols and vapors from the cooking process shall be removed and properly disposed. In most cases, the cost of analytical testing, cleaning and post-testing exceeds the cost of replacement of these articles. While EMD strongly recommends that this apply to furniture and clothing, EMD has no authority to require that property contents be disposed. 9.3.3 “Popcorn” spray-on ceiling coatings may contain asbestos and should not be disturbed unless there is gross staining; any such work must be directed by a Cal/OSHA Certified Asbestos Consultant. A sealant, of the type typically used for asbestos-containing spray-on finishes, should be applied to the ceiling if low concentrations of contaminants are detected. 9.3.4 Some nonporous and semi-porous surfaces (e.g., floors, countertops, tiles, walls and ceilings) can hold contamination from the cooking process, particularly in those areas where cooking and preparation was performed and chemicals were stored. If a surface has visible contamination or staining, complete removal and replacement of that surface is required. This could include removal and replacement of wallboard, floor coverings, concrete slabs, and countertops. If this is not possible, intensive cleaning (see below) could be attempted. Circumstances that prohibit removal and replacement should be described in the Remediation Workplan. 9.3.5 Appliances that were in the room in which cooking was conducted must be disposed (too many surfaces to show sufficiently clean for food preparation or storage). All other appliances associated with food preparation or storage located outside the cooking area must be sampled for analytical testing.

9.4 SURFACE WASHING. Surface washing takes many forms, including pressure washing, detergent-washer washing, solvent (alcohol) washing, steam cleaning, and others. The objective is to remove contaminants to below criteria specified in Section 25400.16 of the H&SC by an efficient and cost-effective method that generates a minimal waste stream. Note that all wash solutions and rinsate must be effectively collected for disposal (see Paragraph 15.0).

9.5 ENCAPSULATION. In cases where porous or semi-porous surfaces (e.g., walls, wood flooring, panels, ceiling, concrete) have had levels of contamination that permitted in-situ cleaning instead of removal and replacement, such surfaces shall be encapsulated with an oil-based paint, varnish, or similar sealant. Water-based latex paints appear to have a greater tendency to permit “bleed-through” than oil-based coatings. The sealant is to be applied after surface washing has been completed. After the sealant has cured in accordance with the


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manufacturer’s instruction, sampling and analysis must be conducted to assure that any remaining contamination is below criteria specified in Section 25400.16 of the H&SC.

9.6 VENTILATION SYSTEM

9.6.1 Ventilation systems tend to collect fumes, vapors and dust, and redistribute them throughout a structure. The vents, stove hoods, ductwork, filters and even the walls and ceilings near the ventilation ducts can become contaminated. Absence evidence to the contrary, all air filters in the system shall be replaced, ventilation registers removed and cleaned, and surfaces near inlets and outlets cleaned. Cleaning of system ductwork should be considered, although the efficacy of duct cleaning is subject to debate; US EPA’s article on duct cleaning is at the following link: http://www.epa.gov/iaq/pubs/airduct.html. 9.6.2 In motels, apartments, row-houses or other multiple-family dwellings, a ventilation system may serve more than one unit or structure. These connections must be considered when evaluating remediation and testing procedures. One strategy is to take samples from adjacent or connected areas/rooms/units, working outward from the lab site until samples show results below criteria specified in Section 25400.16 of the H&SC. 9.6.3 Anecdotal evidence indicates that rooms adjacent to the cooking area may be impacted by active or passive ventilation (distributing fumes and vapors) or by poor chemical handling and hygiene practices. As is the case with other jurisdictions, EMD will require evaluation and possible decontamination of areas adjacent to the cooking area. Such areas may include hallways and other high traffic areas, as well as adjacent rooms. The Consultant shall consider this in the PSA Workplan.

9.7 IMPACTED SOIL AND GROUNDWATER

9.7.1 Impacted soil or groundwater will be investigated and remediated under normal regulatory criteria for hazardous waste sites. Oversight for hazardous waste site remediation will be conducted by the California Department of Toxic Substances Control; if groundwater may be impacted, oversight may be shared with the Regional Water Quality Control Board. These agencies may, under certain circumstances, transfer oversight responsibility to the Site Assessment/Mitigation (SA/M) Unit of EMD. Responsible parties may have the option of requesting the SA/M Unit to provide oversight of the voluntary remediation of the hazardous waste site component of the property; such oversight would be provided on a fee-for-service basis. 9.7.2 The variables associated with hazardous waste site remediation are numerous, and will not be discussed in this document. In the event that the PSA Report identifies potential impacts to soil and/or groundwater, EMD will work with the Property Owner and Consultant to determine the appropriate path for further assessment and mitigation activities and associated regulatory oversight.


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10.0 POST REMEDIATION ASSESSMENT The purpose of the post remediation assessment is to establish that the property has been cleaned up to a level below criteria specified in Section 25400.16 of the H&SC. This assessment should be conducted by the authorized contractor after remediation has been completed and/or the encapsulant has cured. Sampling protocols for the post-remediation assessment will have been defined in the approved PSA Work Plan. In general, those areas of the property for which the PSA sampling indicate levels above criteria specified in Section 25400.16 of the H&SC and were not removed and replaced (e.g. were cleaned, or cleaned and encapsulated) are sampled in the same manner used for the PSA. If all sampling results fall below criteria specified in Section 25400.16 of the H&SC, then the remediation work is completed and the authorized contractor can prepare the Final Report. Any areas that fail the post-remediation sampling are to be further remediated and then re-sampled.

11.0 FINAL REPORT

11.1 TWO OPTIONS FOR COMPLETION. There are two options for the completion of the Final Report.

11.1.1 If the remedial action consisted solely of removal of contaminated surfaces, such as cabinets, floor coverings, sheetrock and similar materials, and post-remediation sampling and assessment is not required by EMD, then the authorized contractor must provide to EMD a Final Report following procedures in paragraph 11.2 certifying the remedial activities have been completed in accordance to the PSA Report. This documentation shall include proof of proper disposal of contaminated items and building materials that have been removed from the property as part of the remediation process. Note that any remediation activity other than removal of contaminated surfaces requires post-remediation sampling and assessment. 11.1.2 If the PSA Report includes actions other than removal of contaminated surfaces (e.g., removal of some surfaces, cleaning of others), the authorized contractor must provide a Final Report establishing in detail that the remediation work has been completed in accordance with the approved PSA Report. This documentation shall include proof of proper disposal of contaminated items and building materials that have been removed from the property as part of the remediation process.

11.2 REPORT COMPONENTS. The Final Report is a technical document, summarizing the work performed as outlined in the approved PSA Work Plan and PSA Report and data collected during the Post Remediation Assessment. The Final Report must be signed and notarized by the authorized contractor responsible for the completion of the PSA and by a Certified Industrial Hygienist (CIH). Components of the Final Report shall include:


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11.2.1 Case Narrative. 11.2.2 Site Description 11.2.3 Summary of PSA findings and recommendations 11.2.4 Summary and documentation of remedial actions 11.2.5 Post-remediation assessment with detailed description and documentation, including lab reports and scaled site map keyed to sample locations 11.2.6 Post-remediation assessment results, with Consultant’s analysis and recommendation.

12.0 NO FURTHER ACTION (NFA) DETERMINATION If EMD determines that the property that has been the subject of a PSA Report does not require remediation or has remediated in accordance with this Plan and Chapter 6.9.1 of the H&SC, EMD shall issue a NFA determination and complete all required actions in accordance with Section 25400.27 of the H&SC.

13.0 REOCCUPANCY CRITERIA

13.1 METHAMPHETAMINE. Pursuant to Section 25400.16 of the H&SC, property contaminated by Clan Lab activity is safe for human occupancy only if the methamphetamine level is less than, or equal to 0.1 microgram per 100 square centimeters (0.1 µg/100cm2 ).

13.2 LEAD AND MERCURY. When it is suspected that the Clan Lab activity had included the use of lead or mercury, a property will be considered safe for human occupancy when the following standards:

13.2.1 The total level of lead is less than, or equal to, 20 micrograms per square foot (20 µg/ft2). 13.2.2 The total level of mercury is less than, or equal to, 50 nanograms per cubic meter of air (50 ng/m3).

14.0 ANALYTICAL AND SAMPLING METHODS

14.1 Analytical methods are driven by the analyte, and sampling methods are frequently driven by the analytical method. Analytical methods for wipe and bulk samples are expected to be from US EPA SW-846, OSHA Sampling and Analytical Methods, NIOSH Analytical Methods, and, in the case of lead, HUD guidelines. 14.2 Methamphetamine samples shall be analyzed by modified Method 8270. According to Washington Department of Ecology-accredited labs, modified Method 8015 is prone to false


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positives. Wipe samples are to be obtained with 11 cm #40 Whatman Filter Paper (p/n 1440-110) or similar wetted with methanol, stored and shipped in appropriate sampling jars. 14.3 EMD will not accept field analyses for clearance samples. This includes the use of colorimetric detector tubes, real-time direct reading instruments such as flame ionization and photo ionization detectors, any type of Hazardous Category evaluation, and Marquis/Methamphetamine reagents, pH paper, or similar.

15.0 LABORATORY REQUIREMENTS All analyses are to be conducted by analytical laboratories which are accredited (Fields of Testing E114-E117) by the California Dept. of Health Service Environmental Laboratory Accreditation Program. Note that this list is not limited to labs in California, as California has ELAP reciprocity with several states.

16.0 WASTE DISPOSAL 16.1 All materials removed from a Clan Lab property as a result of having been impacted/ contaminated by Clan Lab activities (operation, storage, spills, disposal) must receive special handling at the disposal or recycling facility. Examples of such materials are kitchen appliances, drapes, carpets, and building materials. Items such as appliances and furniture must be rendered unusable prior to disposal. 16.2 For any disposed items, EMD will require an inventory, as well as a waste disposal receipt, to be submitted with the Final Report. For items that are required to be disposed as hazardous waste, a copy of the Uniform Hazardous Waste Manifest is required. 16.3 EMD does not regulate the types of wastes accepted by any landfill as each facility has its own permit requirements to meet, and will likely review Clan Lab debris on a case by case basis. It is up to the Contractor to contact the landfill to determine if a specific material removed from a Clan Lab property will be accepted, and the conditions under which it will be accepted.


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17.0 SEPTIC SYSTEMS 17.1 If there is evidence that waste were dumped down a drain, the Consultant will need to work through a process to determine whether a septic system was impacted.

17.1.1 Evaluate tubs, sinks, toilets and similar for evidence of waste disposal. Staining from hydroiodic acid (red/orange) would be a good visual indicator.

17.1.1(a) If there is no evidence of disposal, the task is complete. 17.1.1(b) If there is evidence of disposal, continue to 16.1.2.

17.1.2 Assuming evidence of disposal, determine whether the property is on septic or sewer system. Local water quality agencies, such as City of Sacramento Public Works or the County Sanitation District can assist in this determination. Contact numbers, current in January 2006, include:

Sacramento County Sanitation District: (916) 875-6100 City of Sacramento: (916) 264-5371 City of Folsom: (916) 355-7200 17.1.2(a) If the property is on a sewer system, the task is complete. 17.1.2(b) If the property is on a septic system, continue to 16.1.3.

17.1.3 Obtain a representative sample of the material in the septic tank. Have the sample analyzed for hazardous waste characteristics. Use an ELAP-accredited laboratory appropriate for the analysis.

17.1.3(a) If analysis indicates that the sample is non-hazardous, the task is complete. 17.1.3(b) If analysis indicates that the sample is hazardous, continue to 16.1.4.

17.1.4 Using resources such as the SWRCB tables of disposal facilities (Attachment IV), determine which facility will accept the mixed septic/hazardous waste. Use an appropriately-permitted hazardous waste transporter to pump the tank and transport the contents to the accepting facility. 17.1.5 Information regarding the positive analysis for hazardous waste characteristics shall be provided to the EMD Site Assessment/Mitigation Section, which will evaluate whether remediation action will be required for the leachfield.


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ATTACHMENT I

The Surrogate Method EMD has reviewed a number of sampling methods from a variety of sources, and has determined that a standard method based on the “Proposed Surrogate Method” devised by Bruce Lazarus, CIH, will be the benchmark for evaluating sampling protocols. Lazarus’ paper describing this method was published in the Journal of Clandestine Laboratory Investigating Chemists, Volume 10, Number 2. Most of the material in this Attachment is taken from this article. It should be noted that few individuals outside of the law enforcement community have Lazarus’ experience in Clandestine Laboratory health risks and assessments. His background as a Certified Industrial Hygienist in the environmental remediation and emergency response industry, as well as his extensive work with Clan Lab investigation and remediation, provide him with a unique perspective for designing a cost-effective investigation process. In the Surrogate Method, a limited number of laboratory samples are taken from judgmentally-selected locations throughout the clandestine laboratory site and analyzed for the target analytes. This design method attempts to balance the necessary cost burden of assessment activities against the public health need to ensure that no significant residual contamination is unknowingly allowed to persist uncorrected. The surrogate approach is based on the following concepts:

A. There is a lack of test methods and reference standards for many of the substances, and especially some of the organic drug compounds, which are associated with clandestine lab activities. In short, one can’t feasibly test for all hazardous materials associated with the cooking process, and even if test methods were available, it would be prohibitively expensive to do so.

B. Some target chemicals tend to be more persistent in the environment, both in porous media and on non-porous surfaces, allowing for latent detection.

C. The presence and concentration variability of target chemicals assessed at laboratory sites is assumed to be representative of similar conditions for the remaining clan lab chemicals not specially analyzed for owing to the reasons outlined above. The premise assumes that if the target analytes are detected in significant concentration, then other clan lab method specific chemicals not analyzed for are also present in concentrations of public health interest. Conversely, if the target analytes are not detected, or detected in very low concentrations, it may be inferred, following this presumption, that chemical not analyzed for are also likely to be not present, or present in concentrations low enough not to be of public health concern.

It is understood that these assumptions define a data gap suitable for future study. However, absent an alternative method that concurrently minimizes the cost of investigation while providing adequate information to indicate potential public health risk, the Surrogate Method is the minimum level of site investigation acceptable to EMD.


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EMD Criteria under the Surrogate Method follow.

A. Sample Types. A combination of wipe and bulk samples should be taken utilizing this protocol. Wipe samples should be taken of non-porous surfaces, whereas bulk samples should be taken of porous materials.

1. Wipe samples should be taken of sealed concrete (garage floors), vinyl flooring, sealed wood surfaces, tile, Formica, bathroom fixtures, appliance surfaces, painted surface of good condition, etc.

2. Bulk samples should be taken of unsealed or poor condition concrete and wood surfaces, dry wall, painted surfaces of poor condition, carpeting, carpet padding, upholstery, septic waste, and soils.

NOTE: In some cases, particularly with painted surfaces, a decision must be made if a wipe sample or bulk sample would be more appropriate to recover and identify potential contamination. To address error associate with mass loading of bulk samples, particularly from painted surface and drywall, it may be appropriate to obtain bulk samples using a surface scraping technique.

B. Sample Locations and Quantities

Take one bulk or wipe sample from the following as associated with each major area of the location suspected by history and/or visual observations as being potentially affected by contamination:

1. Each major floor surface. 2. Each major wall surface. 3. Each major ceiling surface. 4. Each major home appliance (e.g., refrigerator, oven, microwave, dishwasher,

washing machine, dryer, etc.). 5. Each major cabinet, counter, and/or built-in feature (e.g., kitchen cabinets,

counters, vanities, etc.). 6. Each bathroom and/or kitchen fixture or grouping of fixtures. 7. Each major furniture grouping.

NOTE: In establishing the number and location of samples at individual property sites, sampling of some locations or items may not be necessary if the need for remediation is apparent by observation or agreement of parties. Examples include fire-damaged surfaces, apparent direct chemical staining or damage, and/or obvious physical damage of an item or feature necessitating removal.

C. Collection Procedures

1. Wipe Samples. Wipe samples should be obtained using the following protocol unless otherwise instructed by the analytical laboratory. Note that these instructions differ from Lazarus’ paper, as lab requirements have been refined. a. Use eight-ounce, wide mouth, borosilicate glass jars having phenolic screw

top lids with Teflon liners.


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b. Prepare each sample by placing a 11 cm #40 Whatman Filter Paper (p/n 1440-110) or similar (see Note) into each sample jar. Add 5 ml of methanol to each pad and close the jar. Use appropriate personal protective equipment when using methanol.

c. Select the surface location to be sampled. d. Squeeze excess methanol from the pad (back into the open jar) before

wiping the sample area. e. Wipe a one hundred square centimeter (100 cm2) surface area, using a

consistent wipe or blot pattern technique (i.e., concentric circle pattern starting in the upper left corner and ending in the center of the area). Use a 10-by-10 cm square template (usually made of Teflon or other material that will not contaminate the sample and is resistant to the solvent).

f. Without allowing the filter to contact any other surfaces, fold the filter with the exposed side in, the fold it again. Return the filter to the glass jar and replace the lid.

g. Wear disposable Nitrile or PVC gloves for each sample taken. Change gloves between samples.

h. Obtain separate wipe samples (separate jar and pads) for each individual analyte, including pH, to be analyzed by the laboratory unless the laboratory explicitly states that multiple analytes can be tested from one pad. Otherwise, if multiple analytes are to be tested, then all wipe samples from a selected location should be of adjacent, contiguous surfaces. Do not re-wipe the same surface.

i. Preservation of the samples for inorganic analysis is not normally required unless otherwise specified by the analytical laboratory.

j. When appropriate, submit a sample blank consisting of a prepared sample jar taken to the field and returned to the laboratory for analysis.

k. Label the jar, attach custody seal, and prepare sample for transport to the laboratory.

l. See Section 4.6.2 for information on compositing samples.

NOTE: In some cases, specific to the surface being sampled, it may be preferable to use sterile gauze pads.

2. Bulk Samples. Bulk samples should be obtained using the following protocol unless otherwise instructed by the analytical laboratory: a. Use four- or eight-ounce, wide mouth, borosilicate glass jars having

phenolic screw top lids with Teflon liners. b. Select the media to be bulk sampled. c. Using an appropriate sampling tool/device, obtain a minimum of 30 grams

for each bulk sample unless the analytical laboratory specifies a different quantity of sample.

d. Wear disposable Nitrile or PVC gloves for each sample taken. Change gloves between samples.

e. Unless otherwise specified by the analytical laboratory, multiple analytes, including pH, may be analyzed from single bulk sample representing each medium to be evaluated.


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f. Sampling tools/device should be cleaned and triple-rinsed with deionized water between each bulk sample or otherwise cleaned following a laboratory-recommended protocol between samples.

g. For scrape samples of paint, etc., a polyethylene tray (or similar capture device) may be taped to the wall surface below the surface area to be scraped. Collect the sample in the tray and then transfer it to the sample container.

h. Preservation of the samples for inorganic analysis is not normally required unless otherwise specified by the analytical laboratory.

i. Bulk samples for organic analysis should be preserved at 4°C (usually applies to septic waste and subsurface soil samples recovered for volatile and semi-volatile hydrocarbon analysis).

D. Target Analytes Analytes specified for analysis should be selected based on individual association with specific Clan Lab manufacturing processes, expected persistence in the environment, usefulness of data interpretation, application of available testing methods, laboratory capabilities, and cost of analysis. The table below provides selected target analytes and test methods appropriate for the most common methamphetamine synthesis routes typically encountered in the United States. This table should be used as a guide only, as it may not be necessary nor appropriate to sample and analyze for every analyte listed.

Target Analytes for Common

Methamphetamine Manufacturing Methods Manufacturing

Method Methamphetamine1 Precursor Hydrochloric Acid (Chloride)

Essential Chemicals (or by-

products)2

Red Phosphorous Modified EPA Method 8270

Ephedrine by Modified EPA Method 8270

EPA Method 300

Total Phosphorous by EPA Method 60103 Iodide by EPA Method 300

Ammonia Modified EPA Method 8270

Ephedrine by Modified EPA Method 8270

EPA Method 300

Total Lithium or Total Sodium by EPA Method 60103 Total Ammonia by EPA Method 350

Mercuric Chloride Modified EPA Method 8270

Phenyl-2-Propanone by Modified EPA Method 8270

EPA Method 300

Mercury by EPA Method 7471A Total Lead by EPA Method 6010

NOTE: approved labs (e.g., ELAP labs) may select methods other than those listed in this table. 1 Results for Modified EPA Method 8270 may be semi-quantitative depending on analytical laboratory capabilities. 2 Select one or more analytes for sampling and analysis, based on property data and assessment needs. 3 Metals analysis may also be performed by EPA Method 6020.


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ATTACHMENT II

Chemicals of Concern Taken from the CSTI Clandestine Drug Laboratory Chemical Identification training manual, the following is a less than exhaustive list of typical lab chemicals. Methamphetamine Methods of Production and Chemicals Typically Used • Hydriodic Acid Method (Ephedrine)

o Ephedrine o Hydriodic acid o Red phosphorous o Sodium hydroxide o Hydrochloric acid o Freon

• Phenyl-2-Propanone Method (P-2-P) o Phenyl-2-Propanone o Methylamine o Methyl Alcohol o Mercuric chloride o Aluminum o Ether o Sodium hydroxide

• Sodium Metal Method (Nazi or Birch) o Ephedrine o Pseudoephedrine o Anhydrous ammonia o Sodium (metal) o Lithium (metal) o Hydrochloric acid


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ATTACHMENT III

Resources Materials used the development of this criteria document include: Guidelines for Cleaning Up Former Methamphetamine Labs

Missouri Department of Health and Senior Services http://www.health.state.mo.us/ResourceMaterial/meth.pdf

Guidelines for Contamination Reduction and Sampling at Illegal Drug Manufacturing Sites Washington State Department of Health, Office of Toxic Substances http://www.doh.wa.gov/ehp/ts/CDL.HTM

Clandestine Laboratory Contaminated Properties: Assessment and Remediation Strategies, Bruce Lazarus, CIH Journal of Clandestine Laboratory Investigating Chemists, V. 10, No.2, April 2000

Illegal Methamphetamine Laboratories University of Arizona College of Public Health http://www.publichealth.arizona.edu/organization/divisions/division3/methlab/index.html

Clandestine Drug Lab Cleanup Program Oregon Public Health Services, Environmental Services and Consultation http://www.ohd.hr.state.or.us/esc/druglab/welcome.htm

Cleanup of Clandestine Methamphetamine Labs (draft) Colorado Department of Public Health and the Environment http://www.gcgllc.com/LEPCHandbook/methlabcleanup.pdf

Meth and Clandestine Drug Labs Minnesota Department of Health http://www.health.state.mn.us/divs/eh/meth/index.html

Surface and Dermal Monitoring for Toxic Exposures Ness, Shirley A. 1994. Van Nostrand Reinhold, New York. W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB PLAN FOR REMEDIATION OF METH PROP.doc

CLANDESTINE LABORATORY FIELD WORKSHEET EMD

INFORMATION Responder: Time: Date: Incident #:

LAW ENFORCEMENT CONTACT

Officer: Phone #: Agency: Report #:

Incident Location: City: Zip Code: Parcel #:

Name of Property Owner: Phone #: Contacted at time of incident?

Address: City: Zip Code:

Name of Occupant(s):

Phone #: Contacted at time of incident?

SITE INFORMATION

Name of Occupant(s):

Phone #: Contacted at time of incident?

Type of Property: Single Family Duplex Apartment Mobile Home Hotel/Motel Other:

Description: Single Story Multi-Story # of Bedrooms:________ # of Bathrooms:_______ Garage: 1 Car 2 Car Other

PROPERTY DESCRIPTION

Status at Time of Incident: Owner Occupied Rental Vacant

Type of Process Used: Entrance Posted Yes No

Photos Taken Yes No

Cooking Location(s): Proximity to Living Area (physical description):

Relative Size of Lab/Complexity:

Length of Cook Time & Source of Information:

CHEMICALS FOUND LOCATION AMOUNT

CLAN LAB INFORMATION

1.

2.

3.

4.

5.

RECOMMENDED SAMPLING/REMEDIATION

LOCATIONS

(USE ADDITIONAL SHEET IF NECESSARY)

6.

ADDITIONAL INFORMATION/

COMMENTS

(USE ADDITIONAL SHEET IF NECESSARY)

W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB WORKSHEET .doc

COUNTY OF SACRAMENTO ENVIRONMENTAL MANAGEMENT DEPARTMENT HAZARDOUS MATERIALS DIVISION 8475 Jackson Road Suite 230 • Sacramento, CA 95826 • Phone (916) 875-8550 • FAX (916) 875-8513

!WARNING! Posted per California Health & Safety Code Section 25400.18(a) - (i)

Materials have been seized at this location that are consistent with the manufacturing and/or use of methamphetamine. Hazardous substances, toxic chemicals, or hazardous waste

products may have been present and remain on or inside this property.

Address: _____________________________________________________________________________________

Date of Posting: ______________________________________

For Further Information Contact: Sacramento County Environmental Management Department

Hazardous Materials Division Phone #: (916) 875-8550

It is unlawful for any unauthorized person to enter the contaminated portion

of this property until the local health officer or designated local agency has advised it is safe to do so.

Any person caught disturbing, destroying, or violating this posted Notice is subject to a civil penalty of up to $5,000.

!WARNING! W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB POSTING.doc

EMD CLAN LAB CLEAN-UP CHECKLIST

DATE OF SITE DISCOVERY:_____________________________ IR #: ______________________________________ ADDRESS: ___________________________________________________________________________________________________

REQUIREMENT COMPLETED IMMEDIATELY: DATE TIME

On-Call Incident Response Team Member responds to location of alleged methamphetamine laboratory activity.

If the site location is in the City of Sacramento, contact the on-call Code Enforcement person. In addition to all materials found and removed from the site, photograph all areas and items that are indicative of

methamphetamine production and associated contamination

Complete Clan Lab Field Worksheet (within 5 days of notification) Post house if cooking has occurred and/or contamination is observed (within 48 hours of notification).

Location of Posting:__________________________________________________________________________

Obtain the Law Enforcement Report and any associated documentation

WITHIN 10 WORKING DAYS (ONCE CONTAMINATION HAS BEEN DETERMINED): Record lien with County Recorder’s Office. Complete form and go to County Clerk’s Recorder’s office located 600 8th

Street, Sacramento, CA. Public counter hours for document recording are M-F, from 8:00 am to 3:00 pm. File lien and research all known persons and/or parties who have an interest in the property.

Complete and send Order by certified mail to all known occupants of property and all persons and/or parties who have interest in the property as listed in the Recorder’s office records.

Send copy of Order to the local code enforcement agency.

WITHIN 1 WORKING DAY OF DATE OF ORDER: Post Order in a conspicuous place on the property. Location:____________________________________________

Responsible Party has 30-days after receipt of the Order to hire a remediation firm. Responsible Party has 30-days to submit the Preliminary Site Assessment (PSA) Work Plan after hiring the

remediation firm.

WITHIN 10 WORKING DAYS OF PSA WORKPLAN SUBMITTAL:

Review PSA Work Plan submitted by property owner to determine compliance with H&SC Chapter 6.9.1.

WITHIN 15 WORKING DAYS OF PSA WORKPLAN SUBMITTAL: Send form letter notifying owner of deficiencies or approval of PSA Workplan

Responsible Party has 90-days to complete remediation work after the PSA Workplan has been approved

AFTER PSA WORK PLAN REMEDIATION COMPLETED: Responsible Party must submit PSA Report after PSA remediation is completed in accordance with the PSA

Work Plan Review PSA Report to determine compliance with H&SC Chapter 6.9.1.

WITHIN 10 WORKING DAYS OF PROPERTY REMEDIATION:

Confirm that the payment has been paid on the lien to EMD.

Release the Lien on the property by completing the form and filing it (via fax) with the County Clerk Recorder’s office. Send No Further Action (NFA) Letter to the property owner and all persons and/or parties who have received the

original notification of Order.

Send a copy of the NFA letter to the local code enforcement agency. Last Revised: April 26, 2006 W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB CHECKLIST 2.doc

County of Sacramento Environmental Management Department Hazardous Materials Division 8475 Jackson Road, Suite 230 Sacramento, CA 95826 Telephone: (916) 875-8550 Facsimile: (916) 875-8513

Certified Mail Number:

) NOTICE OF ORDER ) PROPERTY CONTAMINATED BY METHAMPHETAMINE LABORATORY ACTIVITIES

PROPERTY OWNER: ) [California Health and Safety Code ) Chapter 6.9.1] ) ) Case File No. 06-CO

INTRODUCTION

1.1. Parties. This ORDER is issued by the Sacramento County

Environmental Management Department, Hazardous Materials Division ("EMD")

to ____________________ ("Respondent").

1.2. Site. Respondent is the owner of record for the residence at

_______________________________ Sacramento, CA __________. The

property is described as a single family dwelling.

1.3. Jurisdiction. Pursuant to the California Health & Safety Code

(H&SC) Chapter 6.9.1, Article 4, and with authority granted by the Sacramento

County Health Officer, EMD is responsible for the regulatory oversight of the

remediation of properties and areas contaminated as the result of

methamphetamine production.

1.4 Pursuant to H&SC Section 25400.22(a), a lien will be attached to the

property. This lien will be released when the respondent makes payment to EMD

for costs accrued. Site remediation has been completed.

__________________ __________________ Page 2

DETERMINATION

2.1 Due to the discovery of chemicals that are commonly used in the

production of methamphetamine on _________________, EMD performed a

complete inspection of the property and/or area described in paragraph 1.2.

2.2 This inspection was completed on__________________, and it has

been determined that all or portions of the inspected areas are contaminated as

the result of methamphetamine drug laboratory activity. This contamination

poses a hazard to human health and the environment and may affect personal

effects and furniture within the described property or area.

ORDER

3.1 Use or occupancy of any contaminated areas of the described

property and/or area is PROHIBITED (H&SC Section 25400.00(g)(6)). This

prohibition includes any activities that removes or alters any portion of the

contaminated area.

3.2 The Respondent must comply with all sections of H&SC Chapter

6.9.1 Article 4.

3.3 The Respondent, through an authorized contractor, must prepare a

Preliminary Site Assessment (PSA) Work Plan and a PSA Report in accordance

with EMD’s “Plan for the Assessment and Remediation of Properties

Contaminated by Methamphetamine Laboratory Activities” and H&SC Section

6.9.1. Approval by EMD is required prior to the initiation of any remediation,

removal, or demolition work.

__________________ __________________ Page 3

3.4 All contaminated items or debris must be disposed in accordance

with state and federal regulations. Disposal of these materials at any

unauthorized location may be considered felony disposal of hazardous waste

(H&SC Section 25189.5).

3.5 Until the Respondent receives a determination from EMD that the

property requires no further action, the Respondent shall notify any prospective

buyer in writing of this Order and comply with other requirements pursuant to

H&SC Section 25400.28 (a).

3.6 Until the Respondent receives a determination from EMD that the

property requires no further action, the Respondent shall notify all prospective

tenants that have completed an application to rent an affected dwelling unit or

other property of the Order and comply with other requirements pursuant to

H&SC Section 25400.28 (b).

PENALTIES

4.1 Pursuant to H&SC Section 25400.45(b), failure to comply with all

provisions of this Order is punishable by civil penalty of up to five thousand

dollars ($5,000).

For more information, contact EMD at (916) 875-8550. Dated: ________________ 2006 County of Sacramento Environmental Management

Dennis Green Chief, Hazardous Materials Division

DG:____:________ W:\Data\DRUGLAB\NEW DRUG ORDER FORM 2006\1216 CLAIRE AVE KAY WALLACE\CO00029694 1216 CLAIRE AVE LARRY BROOKS CODE ENF.doc

__________________ __________________ Page 4

DRUG LAB INDUSTRIAL HYGIENISTS AND CLEANUP COMPANIES

The following list of contractors is a partial listing and is supplied as a convenience. This is neither an endorsement nor a certification by the County of Sacrmaento for any business listed. The information listed below may have changed since printing. The County assumes no responsibility or liability for the services provided by the companies on this list. IH/PE COMPANIES Bio Max Environmental 510 724-3100 Kwest Engineering 530 671-1947 Network Environmental Systems

916 353-2360

CLEANUP COMPANIES

Nor Cal Environmental 916 525-1006 PARC Environmental 916 992-5405 RAH Environmental 800 234-7241 Ramos Environmental 916 371-5747 Safety Kleen 916 375-2611

W:\Template\HMD\DRUG LAB\METHAMPHETAMINE LAB TEMPLATE.DOT\METHAMPHATAMINE ENFORCEMENT LETTER.DOT.doc

Recording Requested By:

And When Recorded Mail to:

Name Street Address City State, Zip

Space above this line for Recorder’s use only

NOTICE OF LIEN - METHAMPHETAMINE CONTAMINATED PROPERTY

Notice is hereby given by the Environmental Management Department of Sacramento County

that _____________________________________________________________ (name of owner(s) of record)

owners of the subject real property located in the County of Sacramento, State of California, and more specifically described as follows:

Assessor parcel numbers affected _______________________________________ Also known as (site address):____________________________________________ Are liable for all costs and damages incurred in the removal and remedial actions to abate contamination resulting from the actual or potential production of methamphetamine on the aforementioned site. Said site was determined to be contaminated on ____________________________ (date of determination). This lien for recovery of costs, in the amount of __________________ is recorded pursuant to Health and Safety Code Section 25400.22 and shall have the full force, effect and priority of a judgment lien. Date __________________ ______________________________________________ Local agency official On________________, before me, _________________________Notary Public, personally appeared Dennis Green, Hazardous Materials Program Chief, personally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person or the entity upon behalf of which the person acted, executed the instrument. Witness my hand and official seal Signature___________________________________ W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB NOTICE OF LIEN.doc

Recording Requested By:

And When Recorded Mail to:

Name Street Address City State, Zip

Space above this line for Recorder’s use only

RELEASE OF LIEN - CONTAMINATED PROPERTY: METHAMPHETAMINE

I hereby certify that the Notice of Lien – Methamphetamine Contaminated Property given by the Program Chief of the Hazardous Materials Division of the Environmental Management Department of the County of Sacramento, and recorded in the office of the County Recorder of Sacramento County on _____date_____ is no longer in force or effect. Said notice was filed against the property described as follows:

Assessor parcel numbers affected _______________________________________ Also known as: <Case Address> Owner: Address: County of Sacramento Dennis Green Hazardous Materials Program Chief Date __________________ ______________________________________________ On________________________, before me, _______________________ Notary Public, personally appeared Dennis Green, Hazardous Materials Program Chief personally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person or the entity upon behalf of which the person acted, executed the instrument. Witness my hand and official seal Signature____________________________ Local agency official

Countywide Services Agency Environmental Management Department Hazardous Materials Division Dennis Green, Chief

County of Sacramento

Terry Schutten, County Executive Penelope Clarke, Agency Administrator

Mel Knight, Department Director

8475 Jackson Road, Suite 230 • Sacramento, California 95826 • phone (916) 875-8550 • fax (916) 875-8513 • www.saccounty.net

January 1, 2006 Mr. and Ms. Property Owner 1234 Main Street Sacramento, CA 9XXXX CERTIFIED NO: XXXX XXXX XXXX XXXX

Dear Mr. and Ms. Property Owner: SUBJECT: NO FURTHER ACTION DETERMINATION SITE: 1234 FIRST STREET DRIVE SACRAMENTO, CA 9XXXX

INCIDENT NUMBER: XXXXXX

This notice confirms the completion of site investigation and remedial action for contamination resulting from methamphetamine laboratory activities at the above address. Based upon the submitted Preliminary Site Assessment (PSA) Report, and with the provision that the information provided to this agency is accurate and representative of site conditions, no further remedial action related to this property is required. Please be advised that this determination does not relieve you of any liability under the California Health and Safety Code regarding present or future clandestine drug laboratory activities at this site. This determination also does not relieve you of the responsibility to correct other existing, additional, or previously unidentified conditions at the site that have been documented by (appropriate code enforcement agency) or any other local agency. If you have any questions regarding this matter, please contact me at (916) 875-8473. Sincerely, Elise Rothschild Environmental Specialist IV W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB NFA LETTER.doc






_________________ 2006 ______________________________ ______________________________ ______________________________ CERTIFIED MAIL: Dear _____________________: SUBJECT: PRELIMINARY ASSESSMENT (PSA) WORK PLAN APPROVAL SITE ADDRESS: _____________________________________ _____________________________________________________ INCIDENT NUMBER: __________ We have completed our review of your Preliminary Site Assessment (PSA) Work Plan, dated ________________2006, for the site located at _________________________, ________________, CA _____________. This Work Plan is approved and site assessment work can be initiated pursuant to Chapter 6.9.1, Section 25400.36 of the California Health and Safety Code and the Sacramento County “Plan for the Assessment and Remediation of Properties Contaminated by Methamphetamine Laboratory Activities”. Any changes to the above mentioned PSA Work Plan must be documented and submitted for approval by EMD prior to implementation. If you have any questions, please contact me directly at (916) 875-__ __ __ __. Sincerely, ____________________ Environmental Specialist ER:RA:___ c: _________________________ _________________________ _________________________ W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB PSA WORKPLAN APPROVAL LETTER.doc

Specialist: print this form/write info on it/give to clerical TYPIST: open letter template at:

W:/DATA/FORMSARCHIVE/HMD/IR/DRUG LAB CLAN LAB PSA WORKPLAN APPROVAL LETTER.DOC • Type in information specialist writes on this form. • Resave to Specialist’s directory:

o Example: W:/DATA/ARTZ/10498 DILLARD RD PSA APPROVAL LETTER

CIH Contractor

Property Owner And address

DATE FOR MAILING






_________________ 2006 ______________________________ ______________________________ ______________________________ CERTIFIED MAIL: Dear _____________________: SUBJECT: PRELIMINARY ASSESSMENT (PSA) WORK PLAN DENIAL SITE ADDRESS: ___________________________________ _________________________________________________ INCIDENT NUMBER: _________ We have completed our review of your proposed Preliminary Site Assessment (PSA) Work Plan, dated _____________ 2006, for the site located at 5151 Myrtle Ave., #10, Sacramento, CA 95841. The PSA Work Plan, as submitted, is missing several important elements required under Chapter 6.9.1, Section 25400.36 of the California Health and Safety Code. An amended version of this document containing the required corrections must be resubmitted to our office for follow-up review and approval prior to the initiation of any assessment or remediation work at the affected site. We strongly encourage you to refer to our website www.emd.saccounty.net and review the Sacramento County “Plan for the Assessment and Remediation of Properties Contaminated by Methamphetamine Laboratory Activities” for specific guidance regarding the required elements of a PSA Work Plan. Please contact me at (916) 875-_________ if you have any questions regarding this correspondence or the requirements of the PSA Work Plan. Sincerely, ____________________ Environmental Specialist ER:RA:___ c: _________________________ _________________________ _________________________ W:\Data\FORMSARCHIVE\HMD\IR\DRUG LAB\CLAN LAB PSA DENIAL LETTER.doc

CIH Contractor

Property Owner And address

DATE FOR MAILING

Specialist: print this form/write info on it/give to clerical TYPIST: open letter template at:

W:/DATA/FORMSARCHIVE/HMD/IR/DRUG LAB CLAN LAB PSA WORKPLAN APPROVAL LETTER.DOC • Type in information specialist writes on this form. • Resave to Specialist’s directory:

o Example: W:/DATA/ARTZ/10498 DILLARD RD PSA DENIAL LETTER

Metham

phetamine

Contam

inated Property

Methamphetamine Contaminated Methamphetamine Contaminated Property Cleanup Act of 2005Property Cleanup Act of 2005

Elise Rothschild, Supervising Environmental SpecialistMark Trask, Environmental Specialist

Requires local Health Officer to take specified actions after receiving notification from law enforcement of methamphetamine lab activity.

Authorizes Health Officer to delegate duties to local environmental agency, i.e. CUPA.

Methamphetamine Contaminated Property Methamphetamine Contaminated Property Cleanup Act of 2005Cleanup Act of 2005

Within 48 hours of Notification from Law Enforcement:

The property must be posted with a “warning” sign.

If possible, obtain names of occupants.

Local Agency ResponsibilitiesLocal Agency Responsibilities

Within 5 Working Days of Notification by Law Enforcement:

Conduct an on-site inspection.Complete field worksheet.Make contamination determination.Obtain law enforcement report.


Within 10 Working Days of Determining Contamination:

Record lien with County Recorder. Obtain information on all known persons who have an interest in the property.Prepare and Send Remediation Order (Order).


Order goes to:Property owner, all known occupants, any persons who have interest in the property, as per County Recorder’s records. Local code enforcement agency.

Order must be:Posted in a conspicuous place on the property.

Remediation OrderRemediation Order

Must hire contractor within 30 days from receipt of Order.Owner/Contractor must submit Preliminary Site Assessment (PSA) Work Plan within 30 days after hiring contractor.Owner/Contractor must complete remediation work within 90 days after PSA Work Plan has been approved.PSA Report must be submitted after remediation work has been completed.

Property Owner ResponsibilitiesProperty Owner Responsibilities

Within 10 Working Days of PSA Work Plan Submittal: PSA Work Plan must be reviewed to determine compliance with H&SC 6.9.1.

Within 15 Working Days of PSA Work Plan Submittal:Owner must be notified of deficiencies or approval of PSA Work Plan.

After remediation is complete, PSA Report must be reviewed to determine compliance with H&SC Chapter 6.9.1.

Local Agency Response to the PSALocal Agency Response to the PSA

Established Interim Re-Occupancy Criteria:

Methamphetamine:0.1 microgram per 100 square centimeters.

Lead and Mercury:20 micrograms per square foot.50 nanograms per cubic meter of air.

Methamphetamine Contaminated Property Methamphetamine Contaminated Property Cleanup Act of 2005 Cleanup Act of 2005 –– Other IssuesOther Issues

Property Owner may not clean or remediate themselves.PSA Work Plan and PSA Report must be signed and notarized by contractor and by a Certified Industrial Hygienist.If property owner does not initiate or complete remediation, the City or County may remediate property.Property owner is liable for the remediation costs to the City or County.

Methamphetamine Contaminated Property Methamphetamine Contaminated Property Cleanup Act of 2005 Cleanup Act of 2005 –– Other IssuesOther Issues

Within 10 Working Days of Property Remediation:

Payment due on lien to local agency.Once costs are recovered, local agency must release lien.Local agency must send No Further Action letter to all parties who received Remediation Order.

Tieing Up Loose EndsTieing Up Loose Ends

Maximum $5,000 Civil Penalty for the Following:

Person disturbing or destroying “Warning” posting.Person violating “Warning” posting.Property owner who does not provide a notice or disclosure to potential buyers or renters.Person who violates an Order prohibiting use or occupancy of contaminated property.

EnforcementEnforcement

CONTACT INFORMATION:

Elise Rothschild, Supervising Environmental [email protected]

(916) 875-8473

Mark Trask, Environmental [email protected]

(916) 875-8472

Documents

Clandestine Drug Lab Cleanup